Transfer Pricing Documentation Study - Thomson Reuters

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Transfer Pricing Documentation StudyABC Furniture CaymanABC Furniture (USA)Fiscal Year Ended December 31, 2008FINAL1Table Of ContentsExecutive Analysis for the sale of Furniture fromABC(BVI) to ABC(USA)................................ ..................23Appendix: Legal Entity Financial : Applicable : Comparable Taxpayers(Copy 1 ofFurniture Distribution (Major Group 50)).................................... ..............39Appendix: Comparables : Details of Adjustment SummaryI. OverviewABC Furniture USA (hereafter "ABC (USA)" or the Company ) has prepared this Study to documentthe arm s-length nature of the intercompany transaction between itselfand its affiliate, ABC Furniture(BVI) (hereafter "ABC (BVI)"). ABC (USA), a wholly-owned subsidiary of ABC Furniture cayman (hereafter "ABC ( cayman )") is a manufacturer and distributor of residential home furnishings,headquartered in the cayman Intercompany TransactionThe focus of this Study pertains to the following intercompany transaction for the fiscal year endedDecember 31, 2008: ABC (USA) purchases furniture products from ABC (BVI) for distribution in North functional analysis has been conducted to identify and characterize the relevant intercompanytransaction covered by this Study .

headquartered in the Cayman Islands. II. Intercompany Transaction ... independent companies, effectively measuring the arm’s-length nature of the intercompany ... regulations concerning I.R.C. Section 482 that form the essence of transfer pricing tax law and the

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