Please reference the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations and the 1.482-4 Treasury Regulations documents to answer the following question: What are the available methods per the U.S. regulations to determine transfer prices for intangible property? Which method in your opinion is the most appropriate in GSK's case? What are the difficulties, if any, in the application of your chosen method? Compare:

Comparable Uncontrolled Price

Comparable Profits Method

Profit Split Method

Considering the positions advocated by the Company and the IRS, and your review of the additional print and web resources, what arguments would you make to support IRS's position? GSK's position?

Arguments for GSK's Position	Possible Counterpoints
Arguments for IRS's Position	Possible Counterpoints

What can you conclude in terms of the $8.3 billion claim by the IRS and the fear of GSK that the tax bill would go up to $15 billion?

Requirement 6. What are possible ways for multinational corporations to reduce the odds of negative settlements (involving higher taxes and penalties) with the tax authorities?