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August 28, 2026International Transfer Pricing Journal

The Profit Split Method across Jurisdictions – Report on the United States

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Authors

HSHeatherD. SchafrothESElizabethJ. Stevens

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Overview

Jurisdictional review reveals infrequent use of the profit split method among US corporate taxpayers, indicating primary reliance on advance pricing agreements for complex transfer pricing.

Key Points

  • To examine the regulatory framework, judicial precedent, and practical implementation of the profit split method within the United States tax system.
  • Reviewed United States statutory regulations and case law governing transfer pricing methodologies.
  • Analyzed practical corporate tax filing trends and the utilization of advance pricing agreements.
  • United States taxpayers rarely employ the profit split method despite the existence of comprehensive legal rules and case law.
  • The profit split method is most frequently adopted in formal advance pricing agreements negotiated directly with tax authorities.

Cite This Study

Schafroth et al. (2026) studied this question.

synapsesocial.com/papers/6a914622d15324a1df3a9769https://doi.org/10.59403/3pe806d
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