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A Practical Guide to U.S. Transfer Pricing Rules and Their Application to Intellectual Property Transfers. Intellectual property (“IP”) is a cornerstone of value for many businesses operating in today’s global economy. When companies with related entities in different countries transfer IP, U.S. transfer pricing rules come into play. This article explains the key considerations for U.S. transfer pricing as it relates to intellectual property, offering guidance for business leaders who may be unfamiliar with these rules. Our goal is to clarify the IRS’s approach, the methods for valuing IP, and highlight compliance requirements and potential risks.

For many years, the Puerto Rico Treasury Department (PR Treasury) has been looking for ways to oversee the amount of expenses that entities in Puerto Rico get charged or allocated by related entities outside Puerto Rico. In Puerto Rico, it is very common to have entities operating here as subsidiaries or branches of foreign entities, where the Parent Company or Home Office is in the United States or elsewhere.