Treatment of Business Synergy for Transfer Pricing Purposes: Critical Analysis of Sections 367(d), 482 and 936 of the Internal Revenue Code and Government Proposals

Journal
Castro, L. Freitas de Moraes e
United States
International Transfer Pricing Journal 2012 (Volume 19), No. 2
PriceUSD 45

This article addresses the legal issue arising in the United States when the Internal Revenue Service and taxpayers face cross-border transfers of intangibles in outbound transactions (i.e. situations where the acquirer is a foreign entity), specifically where synergy is the intangible to be valued and taxed under current US transfer pricing rules.