FIN 48, Uncertainty and Transfer Pricing: (Im)Perfect Together?

Financial Accounting Standards Board Interpretation No. 48: Accounting for Uncertainty in Income Taxes (hereafter, FIN48) has changed significantly how corporations must disclose uncertain tax positions. One uncertain tax position experienced by most TNCs is related to the cross-border shifting of income due to its transfer pricing transactions, its characterization of specific transactions as not affecting reportable income or as tax exempt, and its management decision that specific income is not taxable by a foreign tax authority (August 2008). The main areas of interest in this study are a TNC’s disclosures of its uncertain tax positions both generally and specific to transfer pricing. These disclosures are assessed pre- and post-FIN 48 implementation in both a traditional statistical analysis and in a content analysis of the related footnotes to the annual reports for 2006 through 2009. DATA ANALYSIS IN PROCESS.