ComplianceLinks is a suite of services designed to provide Internal Revenue Code (IRC) § 482 economic auditing power to state clients. The modules of the ComplianceLinks section, as well as associated services Chainbridge provides are detailed below. Click on any of the module titles below to see how Chainbridge helps you enforce IRC Section 482.
What is Transfer Pricing?
Explaining transfer pricing can be a daunting prospect, but we’ve made it easy for you to learn what it’s all about here at chainbridge.com
If there is going to be a corporate income tax, it’s only fair that everyone pays it. Chainbridge helps states uncover corporations who haven’t paid theirs. Learn how here.
After a comprehensive analysis of your state’s corporate data, Chainbridge will produce an expert economist report including a complete functional analysis, and a relevant income adjustment for a given taxpayer. Chainbridge takes the complication out of 482 compliance with our revolutionary ComplianceLinks software, and our unparalleled transfer pricing expertise.
IRC §482 Regulations
Our approach in determining a final income adjustment for a particular taxpayer relies on section 482 of the U.S. Internal Revenue Code. It’s a method that’s been employed on the international level for decades, and our patented software along with our unrivaled experience in transfer pricing assures our clients that our analysis is both accurate and authoritative.
Should you choose to couple with Chainbridge, you’ll receive an extraordinary customer experience. We ensure that you’ll have our support every step of the way to the very end. Our analysts have served as experts in numerous court cases, and would be more than willing to offer the same services to your state.
What is Transfer Pricing?
Transfer pricing is concerned with setting and testing intercompany prices for transactions with related parties for tax purposes. At the federal level, transfer pricing is governed by Internal Revenue Code (IRC) § 482.
US Treasury Regulations guide practitioners in the application of the principles of IRC § 482. According to Regulations § 1.482-1(a)(1), the “…purpose of section 482 is to ensure that taxpayers clearly reflect income attributable to controlled transactions, and to prevent the avoidance of taxes with respect to such transactions.” According to Regulations § 1.482-1(b)(1), “…the standard to be applied in every case is that of a taxpayer dealing at arm’s length with an uncontrolled taxpayer.” [emphasis added]
The Internal Revenue Service (IRS) has been distributing, apportioning and allocating income, deductions, credits or allowances to international taxpayers for over fifty years.
Below, you’ll find a simple explanation of transfer pricing in general. While this video, courtesy of the Khan Academy, focuses on international inter-company transactions, corporations are also required to pay corporate income taxes to particular states. By using the same transfer pricing method, these corporations are able to skirt state corporate income taxes.