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.
What does TPM stand for?
TPM stands for Transfer Pricing Methodology
This definition appears somewhat frequently and is found in the following Acronym Finder categories:
- Business, finance, etc.
See other definitions of TPM
We have 200 other meanings of TPM in our Acronym Attic
- Total Productive Manufacturing
- Toulon Provence Méditérranée (French community)
- Trade Promotion Management
- Trading Partner Management (system)
- Transaction Processing Module
- Transaction Processing Monitor
- Transactions Per Minute
- Transceiver Processing Module
- Transfer Phase Midcourse
- Transfer Price Mechanism (finance)
- Transition Probability Matrix
- Transmission Path Monitoring (Ciena)
- Transmission Planning Model (Sprint)
- Transparent Project Management (various businesses)
- Transparent Prolog Machine
- Transplant Procurement Management (various locations)
- Transport Policy Model
- Transportation Planning & Management
- Transportation Protective Measure(s)
- Tree Parity Machine (computer security)
Samples in periodicals archive:
Specifically, the guidelines require that the transfer pricing documentation must have a separate master file--providing information about the multinational group--and a country-specific file, which should document the transactions that the Bulgarian entity was involved in, a description of its functions and risks in the supply chain and a description of the transfer pricing methodology and the reasons for its selection.
Select the appropriate transfer pricing methodology.
APAs give taxpayers the opprotunity to obtain prior approval of their transfer pricing methodology from the IRS and foreign tax authorities.
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.
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.
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.