Examining Approaches to Transfer Pricing Under I.R.C. Section 482

Abstract

I review the methods of transfer pricing adjustment used by the IRS for transfers of tangible and intangible property between related parties. These methods include the comparable uncontrolled price method, the resale price method, the cost-plus method, the comparable profits methodology, the profit split method, and the comparable uncontrolled transaction method. An example, using the comparable profits methodology, is also shown.