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Transfer pricing issues involving corporate supply chains have become increasingly complex and controversial in recent years. Part of this increase is business-driven there is growing international specialization. In the late 1990s, a typical supply chain might have included manufacturing, distribution and a centralized intangible holding company.
But in 2011, that supply chain has grown to add procurement companies, a centralized financing function, contract research and development (RD) centers, and services centers; split manufacturing functions among multiple legal entities; and moved from traditional distribution to internet sales. Managing the transfer pricing implications of such complex supply chains a challenge under the best of...
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