CHAPTER 32
Cost of Capital in Transfer Pricing
Mark Bronson, David Ptashne, and Michelle Johnson
Cost of Capital Estimates in Transfer Pricing
Example: Application of the Income Method
Pretax versus After-Tax Discount Rates and Income Streams
Derivation of Discount Rates for Licensing and Cost-Sharing Scenarios
Size and Country-specific Risk Factors
Asset Definitions and Groupings
INTRODUCTION
In this chapter, we discuss the use of cost of capital in transfer pricing analysis, and elaborate on certain measurement issues that arise specifically within transfer pricing applications. Because the approaches applied in a transfer pricing context often differ from those used for financial reporting requirements (specifically those promulgated under ASC 805), we discuss the interrelationship between these two contexts. Last, we provide a subsection that addresses the treatment of returns to capital in transfer pricing analyses involving global dealing operations. ...
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