Transfer pricing is a dynamic and multidimensional topic that has captured the attention of academicians, corporate executives, and tax authorities for many decades. The issues of transfer pricing are very complex and the stakes are extremely high because more than 40 percent of international trade is trade between related entities. This book examines many important tax and management issues related to transfer pricing. These issues include new transfer pricing regulations and their implications, the selection of proper transfer pricing methods, major environmental variables, and issues concerning the administration of a transfer pricing system. The author also presents many interesting findings from a recent study on U.S. transfer pricing practices.

The author begins by describing the nature of intrafirm transactions in a corporate environment and the significance of intrafirm transactions in international trade. Recent changes and major transfer pricing legislation and regulations in the United States are explained. New transfer pricing regulations in Canada, Japan, South Korea, and the European Community and their implications are also discussed. These are followed by a presentation on research methodology and profile of 143 respondent firms. The author then explains the findings on transfer pricing methods and environmental variables of international transfer pricing. Current transfer pricing practices are compared with those of an earlier study done in 1977. Other issues such as system objectives, resolution of policy conflicts, and policies on outside purchases are covered by this monograph. General conclusions from this research and suggestions for further research are also provided.

Global changes in business and tax environments are having profound impact on the volume and direction of intrafirm trade and transfer pricing strategies. Tang reports on the findings of a survey of 95 Fortune 1000 companies, sponsored by the Institute of Management Accountants, and provides highly relevant information not easily found on how companies are reacting to this new business environment. He covers corporate financial goals and strategies and divisonal performance measurements systems, among other topics, and gives highly detailed case studies based on reports from five major respondents to his survey: Whirlpool, Dow Chemical, Guidant Corporation, Masco, and Eaton. Tang's book is essential, up-to-date reading for upper level students, researchers, analysts, and corporate executives in multinational firms worldwide. Tang starts with a presentation of the major changes in the global business environment and explains their impact on intrafirm trade and transfer pricing. In Chapter 2 he reports results of his questionnaire survey, and in Chapters 3 to 7 examines up close the details revealed in his five corporate case studies. He compares these corporations in Chapter 8, focusing on corporate strategies and financial goals, transfer pricing and performance evaluation practices, and concommitant tax planning strategies. He then relates his case study research to other major findings derived from his questionnaire survey, and ends the book with a general, summarizing, analytical conclusion.