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Transfer pricing study Table of Contents #2

 

SAMPLE TRANSFER PRICING STUDIES

STUDY 1: SIMPLE

 

CANCO, a Canadian manufacturer of widgets sells goods to its U.S. based subsidiary USCO which distributes the widgets in the United States. No comparable uncontrolled price is available.

TABLE OF CONTENTS

  1. Scope and use of report
  2. Executive summary
  3. Statement of facts
    1. Introduction
    2. History of North American operations
    3. Organizational structure - legal and functional
    4. Description of entities
      1. CANCO
      2. USCO
    5. Description of product
  4. Industry analysis
    1. General overview
    2. The U.S. market for widgets
    3. Competitive factors
    4. Customers and distribution channels
    5. Value chain of the widget industry
  5. Functional analysis
    1. Description of transactions
      1. Product flows
      2. Documentation flows
      3. Information flows
    2. Calculation of transfer price
    3. Description of functions
      1. Manufacturing
      2. Research and development
      3. Marketing and sales
      4. Administration and other services
    4. Description of risks
      1. Market risk
      2. R & D risk
      3. Inventory risk
      4. Credit risk
      5. Foreign exchange risk
      6. Product liability risk
      7. Other risks
    5. Assets employed
      1. Working capital
      2. Capital assets
      3. Manufacturing intangibles
      4. Marketing intangibles
  6. Current transfer pricing laws and regulations
    1. Overview
    2. OECD guidelines
    3. Canadian legislation
    4. U.S. regulations
  7. Economic analysis
    1. Introduction
    2. Characterization of the entities
    3. Selection of tested party
    4. Selection of method
    5. Identification and analysis of comparable companies
    6. Data adjustments
    7. Profit level indicators and statistical methods used
    8. Analysis of results
  8. Conclusion and recommendations

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Go to Sample Transfer Pricing Study 2 - Table of Contents

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