(redirected from Transfer Pricing Methodology)
TPMTrusted Platform Module
TPMTotal Productive Maintenance
TPMTimbalan Perdana Menteri (Malay: Deputy Prime Minister)
TPMTalking Points Memo (est. 2000; digital publication)
TPMThe Production Manager
TPMThe Phantom Menace (Star Wars: Episode I movie)
TPMTotal Production Management (UK)
TPMTechnology Project Management (various organizations)
TPMToulon Provence Méditérranée (French community)
TPMTivoli Provisioning Manager (IBM)
TPMTensão Pré-Menstrual (Portuguese: Pre-Menstrual Syndrome)
TPMTentative Parcel Map (property records; various locations)
TPMTraditional Power Management
TPMTivoli Privacy Manager
TPMTrack Popup Menu
TPMTrack Personalization Memory
TPMTrack Program Memory
TPMTire Pressure Monitor
TPMTotal Print Management
TPMToshiba Power Management
TPMTivoli Provisioning Manager
TPMTicket Processing Management
TPMTotal Polar Material (cooking oil)
TPMTopiramate (medicine)
TPMTrade Promotion Management
TPMTechnology Park Malaysia
TPMTrading Partner Management (system)
TPMTotal Productive Management
TPMTechnological Protection Measures (DRM, digital locks, copyright protection, etc.)
TPMThird Party Manufacturer
TPMTechnical Project Manager
TPMTotal Particulate Matter
TPMTransactions Per Minute
TPMTechnical Program Manager
TPMTransplant Procurement Management (various locations)
TPMThird Party Maintenance
TPMTotal Preventive Maintenance
TPMTotal Productive Manufacturing
TPMThe People's Mosquito (aviation; UK)
TPMTotal Production Maintenance
TPMTechnical Performance Measurement
TPMTire Pressure Monitors
TPMTransaction Processing Monitor
TPMTujuan Pembangunan Milenium (Indonesian: Millennium Development Goals; United Nations' objectives)
TPMTrust Property Management
TPMThe Philosopher's Magazine (UK)
TPMTylenol PM
TPMTransparent Prolog Machine
TPMTablets per Minute (manufacturing)
TPMTicketed Point Mileage
TPMTransition Probability Matrix
TPMTotal Pallet Management (logistics)
TPMThird Party Marketing
TPMTransfer Pricing Methodology
TPMTelecommunications Project Manager
TPMTimber Products Manufacturers (Spokane, WA)
TPMTotal Particulate Mercury
TPMTerminating Point Master (Bellcore)
TPMTransparent Project Management (various businesses)
TPMTurning Point Ministries
TPMToday People Matter (business philosophy)
TPMTransfer Phase Midcourse
TPMThe PokéMasters (website)
TPMTechnical Performance Metrics
TPMThe Pentecostal Mission
TPMTeam Performance Model (Drexler/Sibbett)
TPMTransport Policy Model
TPMTop Image Systems, Ltd. (former stock symbol; now TISA)
TPMTree Parity Machine (computer security)
TPMTriumph Prophetic Ministries
TPMTerminal Phase Midcourse
TPMTwo-Phase Modeling
TPMTransportation Planning & Management
TPMTransaction Processing Module
TPMThermal Power Monitor
TPMTelemetry Processor Module
TPMTechnical Performance Monitoring
TPMTerrain Profile Mode (military aviation radar)
TPMTwo-Potential Model
TPMTape Preventive Maintenance
TPMTransceiver Processing Module
TPMTest Planning Meeting
TPMTheremin-Playing Module
TPMTeen and Parent Mediation
TPMTwo Procedures Modem (ITU-T)
TPMTeleProfessional Magazine
TPMThermal Prestressing Method (steel structures)
TPMTransfer Price Mechanism (finance)
TPMTechnician's Pocket Manual/Handbook
TPMTransportation Protective Measure(s)
TPMTelephone Pioneer Museum
TPMTransmission Planning Model (Sprint)
TPMTechnology Planning & Management
TPMTri-Partite Meeting
TPMTransmission Path Monitoring (Ciena)
TPMTopflite Print Management (UK)
TPMTechnologies Process Monitoring
TPMTemporary Program Manager
TPMTodo Para Mañana
TPMTwists Per Minute
References in periodicals archive ?
It is not clear from the example why the profit split method is the most appropriate method and why the tea sold by A Co to B Co cannot be valued under a traditional transfer pricing methodology. The facts in this scenario could justify the use of the profit split method in almost any situation (e.g., A Co manufactures Product X using extensive proprietary manufacturing know-how and B Co owns the tradename and trademark, which are both unique and valuable).
If the multinational clearly articulates the relevant facts and uses these facts to select and apply its transfer pricing methodology for the key intercompany price issues, the roadmap instructs the IRS team to consider the documentation properly and hopefully not pursue a transfer pricing issue where the results were reasonable.
* Advanced pricing agreement (APA): An agreement between the IRS and a taxpayer on the transfer pricing methodology to be used in allocating income, deductions, credits, or allowances between two or more organizations or businesses controlled by the same interests.
96-53, the Service usually does not begin its formal analysis of a taxpayer's proposed transfer pricing methodology (TPM) until the taxpayer files an APA request and pays the user fee.
APAs give taxpayers the opprotunity to obtain prior approval of their transfer pricing methodology from the IRS and foreign tax authorities.
In 1991 the Internal Revenue Service (IRS) established the Advance Pricing Agreement (APA) program, allowing a taxpayer to request that the IRS, and potentially other countries, prospectively approve its transfer pricing facts, transfer pricing methodology, and arm's-length range of results.
This agreement encompasses the parameters of prospective transactions and a transfer pricing methodology, and it is designed to sharply limit the audit risks emanating from these transactions.
Revenue procedure 91-22 requires the taxpayer to propose a transfer pricing methodology and present documents showing it produces arms-length results in transactions to be covered by the APA.
In addition, a functional and risk analyses of Company S may be required to enable the application of traditional transfer pricing methodology without resorting to a profit split.
(17.) See, e.g., paragraph 108 ("caution should be exercised in adopting a transfer pricing methodology that too readily assumes that all residual profit from transactions...
Assuming the transfer pricing methodology used was selected in good faith and the taxpayer makes reasonable efforts to support its transfer-pricing methodology by creating and maintaining contemporaneous documentation of the methodology, any proposed adjustment would arise solely because the CRA economist disagrees with the taxpayer's analysis of the transfer-pricing methodology.
For example, adoption of SFAS 123-R (relating to stock option expense) required taxpayers to review and ultimately alter the internal computations supporting their transfer pricing methodology to take into account stock option expense.