Page 46 - International Taxation IRS Training Guides

Income Shifting Inbound

Inbound Transfer
Pricing
Services Example

FP • FP wholly
owns U.S. Sub

tax jurisdiction.
• FP is in a low

Sub is providing Research
$ Services • U.S.
& Development
services to FP.

Sub includes FP payments
Sub
U.S. • U.S.
in income.

• Incentive to understate the
services value.

44