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Transfer pricing is the largest tax and accounting issue for multinational entities with substantial related party transactions. It is a complex valuation concept that impacts taxable income in multiple jurisdictions, customs valuations, state taxes, and financial reporting. The transfer pricing issue is present in approximately half of United States import and export transactions, and has recently produced multiple cases involving disputes over billions of dollars of tax, penalties and interest.

This book provides a comprehensive overview of transfer pricing, written by a 30-year practitioner, 20-year teacher of transfer pricing. It explains the business need and policy underpinnings for transfer pricing and the unique concepts that drive transfer pricing analysis. The book employs charts, diagrams, and formulas to explain the individual steps in transfer pricing analysis and how to apply that analysis to different types of transactions. Finally, it explores penalty rules, controversy procedures, and ways to avoid transfer pricing disputes.

This book will be invaluable to in-house tax lawyers and practitioners of international tax at all levels, as well as to LL.M., M.S.T., and M.B.A. students studying current issues in global businesses.