Transfer pricing rules for transactions involving low-tax countries : United States

Part of a comparative survey dealing with the particular constraints and opportunities connected with the relationship between transfer pricing policy and tax and business planning from both a domestic and a treaty law perspective. This article provides a brief historical overview of the use of low-tax countries and the response of the IRS (through audits) and legislative responses (through changes in transfer pricing laws). The current state of regulation and IRS practices will also be discussed.