Transfer Pricing Documentation Study - Thomson Reuters

Transfer Pricing Documentation StudyABC Furniture CaymanABC Furniture (USA)Fiscal Year Ended December 31, 2008 FINAL1 Table Of ContentsExecutive Analysis for the sale of Furniture fromABC(BVI) to ABC(USA)..23 Appendix: Legal Entity Financial : Applicable : Comparable Taxpayers(Copy 1 ofFurniture Distribution (Major Group 50))..39 Appendix: 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 .

Transfer Pricing Methods The regulations provide guidance and set forth the general methodology for determining and evaluating arm's length prices for the transfer of tangible property, the license of intangible property, the provision of services, and loans by or between related parties. The regulations also provide

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