Talk:Transfer pricing/Archives/2017

Seeking objections
Fellow Earthlings:

I believe this page needs a overhaul and that I'm in a good position to do it. There's some good stuff in here, but there are a number of issues (in no order) that obscure it:

1. Much of the information is dated: The last four years or so have seen an unprecedented flurry of activity in this area (see the base erosion and profit-shifting (BEPS) project and country-by-country (CbC) reporting if you aren't familiar) but other than the handful I've added, there are no references to major recent developments.

2. There are a number of subtle technical errors, some of which I've already fixed: It would take some time to explain these, and so I offer to provide examples and explanations upon request.

3. Some sections drown the reader in excessive and distracting detail: The whole "economic theory" section isn't very useful and if people are seeking guidance on how to perform a comparability analysis in a sec. 6662 study, they should refer to the applicable laws or regulations.

4. The sequence isn't ideal: The best example is the "profit allocation" section near the top. This is about alternative approaches to intra-group profit allocation that could replace transfer pricing. I don't think it makes sense to begin a page about a regulatory framework by talking about what could replace it.

5. There many unsourced statements: Res ipsa loquitur.

If there are no protests, I will begin making the page more accurate, concise, and up-to-date. However, I will make every effort to preserve as much material as I can. As I said, there's some good stuff in there.

I say this only for the purpose of disclosure and to allow people to fully evaluate my proposals: I worked as a transfer pricing consultant for about eight years, I focused on tax in law school, and my current job is to write about transfer pricing for a major trade periodical (Tax Notes / Worldwide Tax Daily) (http://www.taxnotes.com/document-list/contributors-authors/finley-ryan?subscribed=1). I'm not claiming any kind of special authority, but I think I can make a valuable contribution by updating and reorganizing this page.

I would be more than happy to discuss these things should anyone wish to do so.

Ryanmsfinley (talk) 22:56, 6 January 2017 (UTC) Ryanmsfinley (talk) 22:56, 6 January 2017 (UTC)

Very Well, Then
I shall proceed. If anyone would like to get into the details of what I'm doing and why, I'll be monitoring this page closely.

Ryanmsfinley (talk) 17:05, 7 January 2017 (UTC)


 * I'll try to pitch in as well. Initial thoughts are that it looks a bit US centric and it needs more of an overarching plan of what it's trying to convey. I'll post up proposed changes here once I've had a chance to get my head around what's already in the article. User39118114 (talk) 08:53, 9 February 2017 (UTC)

Appeal for "Subject-Matter Expert" Status and Citation to Self-Published Article
I wanted to disclose that I cited to a self-published article based on the guidelines for subject-matter experts and citations to self-published sources. My name is Ryan Finley and I'm responsible for the most of the transfer pricing coverage for Worldwide Tax Daily at Tax Analysts, a well-respected tax law news source. I've been working on revamping the page in spurts over the last few months.

There was a particular point made in the previous version that I wrote about a couple of months back. I cited my article because it's honestly the most relevant article I know of, and I don't see any real way the citation could produce any personal benefit. I tried to be discreet, including by leaving the author field blank. I will offer no protest if someone wants to replace it with a suitable alternative (or anything else, honestly).

The citation is currently at footnote 6, immediately following "although their rules can differ on some important details":

"The Year in Review: The Year of the Many Arm's-Length Standards". 85 Tax Notes Int'l 25 (2017-01-02). Tax Analysts. Retrieved 2017-02-27.

Ryanmsfinley (talk) 01:34, 1 March 2017 (UTC)

External links modified
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