U.S. transfer pricing rules require U.S. taxpayers to report arm's length results on their U.S. federal income tax returns. The reported results of transactions with related parties must be consistent with the results that would have been realized by uncontrolled taxpayers in similar circumstances. In practice, U.S. taxpayers commonly demonstrate compliance with this requirement by showing that their profitability on transactions with related parties is consistent with the profitability of comparable companies engaging in comparable transactions. For example, a U.S. distributor of imported goods might benchmark its operating margin for a tax year against the operating margins of independent distributors, with such information being obtained from public financial disclosures.
The introduction of unanticipated costs into a supply chain can have significant implications for transfer pricing purposes. An immediate issue is determining which affiliate – the U.S. distributor, a foreign manufacturer, a foreign principal company, or some combination – should bear the cost to the extent it is not passed on to customers. Under the arm's length standard, that depends on, among other things, the allocation of risk among the parties, as evidenced from intercompany agreements and course of conduct, and relative bargaining position. Another issue is how to implement changes to transfer prices to ensure arm's length results.
For example, Walmart has Walmart USA Inc, and Walmart Cayman Island
Walmart Cayman Island Ltd. sign contract to buy a shirt for $5, and sell the shirt to Walmart USA for $20. Walmart USA sell the shirt to consumer for $25.
So out of $25 paid by consumer,
$5 goes to Walmart USA, that pays for stores and workers, and profit is 0, tax is 0.
$15 goes to Walmart Cayman Island, keeps $15 tax free.
$5 goes to Chinese factory.
$20 count as Chinese import, add to the trade deficit to USA.
从美国买东西，实打实的原材料和农产品。
从中国买东西，美国公司给中国厂商5元钱，用海外公司涨价到20元卖给美国境内公司，再25元卖给消费者。进口价20元里面15元被节流到美国公司在海外纳税天堂成立的子公司，钱就存在那里免税。
所以中美贸易逆差，相当大的一部分是美国公司赚美国人的钱，逆差是美国内部矛盾的体现。美国无工作蓝领，不需要乖中国蓝领，而是要怪美国资本家。
Workers of the world, Unite?
不是有那老川给的90天嘛
U.S. transfer pricing rules require U.S. taxpayers to report arm's length results on their U.S. federal income tax returns. The reported results of transactions with related parties must be consistent with the results that would have been realized by uncontrolled taxpayers in similar circumstances. In practice, U.S. taxpayers commonly demonstrate compliance with this requirement by showing that their profitability on transactions with related parties is consistent with the profitability of comparable companies engaging in comparable transactions. For example, a U.S. distributor of imported goods might benchmark its operating margin for a tax year against the operating margins of independent distributors, with such information being obtained from public financial disclosures.
https://www.millerchevalier.com/publication/tariff-increases-create-transfer-pricing-challenges-us-importers
Transfer Pricing 就是美国公司（US taxpayer）和一个子公司（related party）虚构一个arm's length transaction。规定是只要母公司和海外子公司的交易对比母公司与其他公司交易，只要profitability类似就可以。
那么太好搞了，大家都从中国进口，买给美国公司们都是一个价，也就是说，大家都避税，那么避税做法就是基准线。
挑战是什么？
The introduction of unanticipated costs into a supply chain can have significant implications for transfer pricing purposes. An immediate issue is determining which affiliate – the U.S. distributor, a foreign manufacturer, a foreign principal company, or some combination – should bear the cost to the extent it is not passed on to customers. Under the arm's length standard, that depends on, among other things, the allocation of risk among the parties, as evidenced from intercompany agreements and course of conduct, and relative bargaining position. Another issue is how to implement changes to transfer prices to ensure arm's length results.
在关税下面，到底是美国公司，海外工厂，还是海外子公司负担关税问题，如何分配关税负担而符合arm's length transaction，是一个税务挑战。
但是，不要担心，总会有办法的。
1/3的至少一个月内exempt
还有更多突击的都是绕去第三国的
https://americansfortaxfairness.org/files/TheWalmartWeb-June-2015-FINAL1.pdf
For example, Walmart has Walmart USA Inc, and Walmart Cayman Island
Walmart Cayman Island Ltd. sign contract to buy a shirt for $5, and sell the shirt to Walmart USA for $20. Walmart USA sell the shirt to consumer for $25.
So out of $25 paid by consumer,
$5 goes to Walmart USA, that pays for stores and workers, and profit is 0, tax is 0.
$15 goes to Walmart Cayman Island, keeps $15 tax free.
$5 goes to Chinese factory.
$20 count as Chinese import, add to the trade deficit to USA.
看明白了吗，还相信中美贸易逆差都被中国赚走了吗？
这种头部高科技有可能， GOOLGLE 估计也又可能