Transfer Pricing Questions
UHY
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1
If a company is buying and selling in a foreign market for the first time, what proactive steps should it take with regards to transfer pricing?
2 What are the mechanics of a transfer study?

What exactly do you produce as a result of such a study?
3 How do intangible assets like patents or licenses apply to transfer pricing?
4 What is the concept of contemporaneous documentation and where does it apply in a transfer pricing situation?

What information is contained in the UHY International Global Transfer Pricing Guide?
5 What are the dangers of taking a "wait and see" approach to transfer pricing to produce the required reporting after a taxing authority makes a claim?
6 Can you further explain the notion of related parties?
7 Is a transfer pricing study a one-time event, or are there required updates? How often?
8 How much does a transfer pricing study cost?

What other studies or analyses are comparable in their scope?
9 Some countries have no penalties related to transfer pricing.

So why bother doing a study for returns filed in these countries?
10 What are the implications for a publicly-traded company as it relates to transfer pricing?
11 How does transfer pricing relate to FIN 48 compliance for companies in the U.S.?
12 So if I'm not a publicly-traded company, do we need to worry about transfer pricing?
13 What types of transactions and companies have UHY International member firms worked on together?
14 Would a transfer pricing study help determine in which foreign country we should consider business - even before we do so for the first time?
15 Can you give us an idea of the scale of penalties from taxing authorities in "high penalty" countries cited such as...Canada?
16 The U.S. Commerce Department issued a global trade report in June citing that Singapore was one of the most "global friendly" countries.

Could one of the reasons be that Singapore has no penalty for transfer pricing violations?
17 It was noticed that of all the Eastern European countries, only Hungary had transfer pricing regulations in effect.

Would it be better, therefore, to set up operations in Slovakia or Slovenia to avoid the hassle?
18 We are considering importing finished goods - i.e. shoes, from Argentina to the U.S. We are working on an agreement with a manufacturer in Buenos Aires, which would be a new relationship.

What taxes would we be subject to?

Does transfer pricing apply here?
19 How can transfer pricing help determine which jurisdiction in which to hold an intangible asset?

Is this part of a tax planning process?
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Click on question on the left to hear the response from a UHY International tax expert during a recent global meeting on current issues related to transfer pricing.