Accounting for Income Taxes: Uncertain Tax Positions in Transfer Pricing (Portfolio 6910)

The Accounting for Income Taxes: Uncertain Tax Positions in Transfer PricingPortfolio provides guidance on determining the units of account and identifying uncertain tax positions; recognizing uncertain tax positions; and evaluating the arm’s-length nature of intercompany pricing. It further explains measurement analyses; disclosures; and the key stakeholders affected by ASC 740-10 in relation to transfer pricing.

The first part of the Portfolio discusses ASC 740-10 and its application to transfer pricing, including a brief overview of the transfer pricing regulatory environment. The authors explain their approach to determining the unit of account for a transfer pricing position, identifying and documenting uncertain tax positions, and applying initial filters.

The Portfolio also covers the recognition of uncertain tax positions and evaluating the arm’s-length nature of intercompany pricing, specifically, key considerations when evaluating transfer pricing exposures.



Table of Contents