Barnes Dennig Transfer Pricing After Tax Reform and COVID-19 120920 - BD | Page 34
WHAT SHOULD MULTINATIONALS CONSIDER ? INBOUND
For profitable companies - consider reducing inventory prices and royalties
• More US activities = lower transfer prices
• New US plant = lower component prices
Result- More U . S . income / Less overseas income
• 21 % rate vs . higher rate overseas
• Additional Customs duty savings ?