Barnes Dennig Transfer Pricing After Tax Reform and COVID-19 120920 - BD | Page 6

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WHY IS TRANSFER PRICING IMPORTANT ?

Starbucks – U . S . IP Owner

Royalties

Starbucks – U . K . Retail Shops

Roasted Beans

Starbucks – Switzerland

Coffee Beans

Starbucks – Netherlands Coffee Roaster

Question : where should profits be generated ?