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

Elizabeth Steven and Heather Schafroth co-authored the article "The Profit Split Method across Jurisdictions – Report on the United States" in the IBFD International Transfer Pricing Journal, 2026, volume 33, number 4a.

For the full article, please visit IBFD's website.

Overview
The United States has robust rules and some case law dealing with the profit split method (PSM). US taxpayers use the method relatively rarely, but most commonly in the context of advance pricing agreements. This article is part of a special issue of the International Transfer Pricing Journal on the application of the PSM across jurisdictions. The other articles include the General Report and contributions on Belgium, France, Germany, Ireland, Italy, Korea, the Netherlands, Portugal and Spain.