CRA Insights

Insights: Transfer pricing is not just an international issue

April 13, 2021
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In this issue of Insights, we discuss how states are seeking additional ways to collect revenue, including transfer pricing audits. This is particularly relevant for states that do not require that a taxpayer calculate state tax liability on a combined or consolidated basis.

US federal transfer pricing principles are generally used to allocate income between affiliated companies in different states in the same manner as US federal regulations set forth the profit allocation between legal entities across international borders.

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