We have one of the largest practice groups in the country devoted to servicing financial institutions, with many of our partners and associates devoting their full attention to the representation of financial institutions in corporate transactions, securities and regulatory matters.
The Financial Institutions Group has again received both national and Chicago recognition in the rankings listed our firm as one of the top firms in the nation in number of announced bank and thrift merger and acquisition transactions during the past 10 years.
Because transfer pricing is a niche area for practitioners, this article gives a general overview of major transfer-pricing issues facing practitioners from a financial reporting and tax perspective. A transfer price is the price charged between related parties (e.g., a parent company and its controlled foreign corporation) in an intercompany transaction.
These are described under the respective risk category.
We use competitive and environmental analyses and market studies to identify not only risks but also opportunities with a positive impact on the design of our products, the efficiency with which they are produced, their success in the market and our cost structure.
The Volkswagen Group has recognized provisions arising from the diesel issue, in particular for the upcoming service campaigns, recalls and customer-related measures as well as for legal risks, but also for residual value risks.
Due to existing estimation risks particularly from legal risks, criminal and administrative proceedings, higher expenses for technical solutions, lower market prices, repurchase obligations and customer-related measures, further significant financial liabilities may emerge.
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Hence, a company’s transfer-pricing policies can directly affect its after-tax income to the extent that tax rates differ across national jurisdictions. 482 gives the IRS the authority to adjust taxable income between two related parties to more accurately reflect the income earned by each party. Generally, a controlled transaction meets the arm’s-length standard if the income from the transaction is consistent with the income that would have been realized if unrelated taxpayers had engaged in a comparable transaction under comparable circumstances. Provision of intragroup services (e.g., call center support, development of marketing plans, and legal and accounting services), intragroup financing, and the use of intellectual property legally owned by a particular group member are all examples of transactions subject to scrutiny under Sec. Determining a company’s transfer prices requires identifying where value is created in an organization and transferred across group members. Taxpayers choose an appropriate economic method specified in Regs. 1.482-3(a) to determine a range of arm’s-length prices (or profits) (see Regs. The transfer price ultimately used to determine taxable income across borders is considered to be at arm’s length if it falls into the range computed. K.-based parent, Glaxo Smith Kline plc, through its worldwide operating group (Glaxo Group) for cost of goods sold, royalties, and other expenses, related in part to manufacturing and distributing Zantac and other prescription drugs. According to the results of a 2010 survey of multinational enterprises by EY (, available at tinyurl.com/ncu83nd), 32% of respondents ranked transfer pricing as one of the most important tax challenges facing their group.
Any transfers of economic value among related parties must meet the requirements of Sec. Not only does it apply to the transfer of tangible goods (e.g., a foreign manufacturing unit sells its output to a U. Typically, value can be characterized and the comparability of a transaction with one between unrelated parties can be determined by factors including the assets used, the risks assumed, and the functions performed by each group member in an intercompany transaction (Regs. THE DIFFICULTY IN APPLYING TRANSFER PRICING Transfer pricing is in the cross hairs of tax policy as it relates to the competing objectives of three parties: the revenue-maximizing objective of the domestic tax authority, the revenue-maximizing objective of the foreign tax authority, and the tax-minimizing objective of the taxpayer. Two-thirds of respondents reported undergoing a transfer-pricing audit, compared with only 52% in EY’s 2007 survey.
Where they can be assessed, risks and opportunities that we expect to occur are already reflected in our medium-term planning and our forecast.