Information on Transfer Pricing

Gao ID: GGD-94-206R September 15, 1994

Pursuant to a congressional request, GAO provided information on how the Internal Revenue Service (IRS) resolves transfer pricing tax code issues. GAO noted that: (1) an IRS internal audit report pointed out problems with some international management information systems and IRS is improving them; (2) from fiscal year (FY) 1989 through FY 1993, about 40 to 50 foreign-controlled and U.S.-controlled companies had total proposed adjustments of more than $20 million; (3) the highest amount of total adjustments occurred in FY 1990; (4) sustention rates for FY 1987 through FY 1993 ranged from 24 percent to 52 percent; and (5) three of the four major court cases on transfer pricing issues decided in 1993 and 1994 resulted in mixed outcomes for IRS and one case was decided in the taxpayer's favor.

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