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  • About
  • The Global ETD Search service is a free service for researchers to find electronic theses and dissertations. This service is provided by the Networked Digital Library of Theses and Dissertations.
    Our metadata is collected from universities around the world. If you manage a university/consortium/country archive and want to be added, details can be found on the NDLTD website.
1

Transfer Pricing: Current Problems and Solutions

Wu, Ronald 01 January 2010 (has links)
The current problems and possible solutions surrounding United States transfer pricing regulations are discussed and studied. The schemes large multinational companies are implementing to legally evade taxes are uncovered as the financial effects to the United States Treasury and government are becoming material. The benefits for these schemes are financially advantageous for corporations as they are able to report larger profits and higher returns for investors. But this is being done at the expense of our government. Corporations are finding ways to escape the high U.S. corporate tax rate and lower their global tax liabilities by allocating income to lower tax jurisdictions. Tax havens like Ireland or Bermuda are popular to have subsidiaries which hold a corporations intangible property. Five United States Tax Court cases concerning transfer pricing are studied and the outcomes are analyzed. The current problems studied from these cases are, shipping intangible property, valuing intangible property, the arm’s length standard. The possible solutions to these currents problems are by no means easy to solve and no one revision can relieve all the problems. The arm’s length standard is the corner stone to the current problems and if the government can find a way to better enforce the standard or replace it, it will be a large step in the right direction.

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