Economic and Accounting Rates and Concepts Should Not be Conflated.- Economic vs. Accounting Profit Rates.- Overview and Critique of Existing Transfer Pricing Methods.- Alternative and Supplementary Approaches to Transfer Pricing.- Some Alternative Approaches to Transfer Pricing.- Case Studies.- Intercompany Sale of Diamonds.- Intercompany Sale of Medical Devices.- Performance of Intercompany Services.- Replication of Internet-Based Business Model.- Sale of Assets with Embedded Intellectual Property.- Provision of CDN Services to Third Parties.- Global Trading of Commodities.- Decentralized Ownership of Intellectual Property.- Conclusions.- Concluding Observations.
Discusses economic underlyings of existing methods and proposes alternatives
Detailed analysis of case studies drawn on the author's professional experience
Enables professionals in companies to perform transfer pricing analyses
Incorporates the new US services regulations issued in July 2006 and the new cost-sharing regulation expected to be published late 2007/early 2008