Schedule P (Form 1120-FSC) (Rev. 9-2017)
b. Aggregate on tabular schedule. The
FSC may choose to aggregate its
Item A—Product or Product Line.
transactions on a tabular schedule rather
Purpose of Schedule
Enter the product or product line that
than on Schedule P. To do so, file one
Use Schedule P to figure an allowable
meets one of the two standards below.
Schedule P, entering only the taxpayer’s
transfer price to charge the FSC or an
name and employer identification
1. The principal product based on the
allowable commission to pay to the FSC
number (EIN) at the top of Schedule P.
North American Industry Classification
under the administrative pricing rules
Also, check box 1b. Attach a tabular
System (NAICS) (see the last page of the
discussed below. The transfer price or
schedule to the partially completed
Instructions for Form 1120-FSC).
commission is used to allocate foreign
Schedule P, reporting all information as if
2. A recognized industry or trade use.
trading gross receipts from the sale of
a separate Schedule P were filed for
export property or from certain services
each aggregate of transactions
Note: If the FSC used the Standard
between the FSC and its related
described in 1a above. Also see Format
Industrial Classification (SIC) codes for
of tabular schedules on page 3.
Schedule P in prior tax years, it may
complete item A based on the SIC codes
Related supplier. Under Regulations
Note: To be eligible for either of the
for the current tax year.
section 1.482-1(a), a related supplier is
aggregate reporting formats described
an entity that is owned or controlled
above in 1a or 1b, the FSC and its
Item B—Basis of Reporting. The FSC
directly or indirectly by the same
related supplier must maintain a
must indicate the basis on which the
interests as the FSC.
supporting schedule that contains all
amounts on Schedule P were
information that would be reported if a
determined using either the transaction-
Filing the Schedule
separate Schedule P were filed for each
by-transaction basis or an election to
transaction. The supporting schedule
File the schedule for an FSC that has
should not be filed with the Schedule P.
foreign trading gross receipts during the
Except for certain small FSCs electing
tax year from:
c. Tabular schedule of transactions.
to group transactions (discussed below),
Instead of aggregate reporting, the FSC
FSCs should not file a separate
• The resale of export property or from
may choose to report transactions on a
Schedule P for each transaction or each
certain services, or
tabular schedule. File one Schedule P,
group of transactions.
• The disposition of export property or
entering only the taxpayer’s name and
1. Transaction-by-transaction. If the
from services in which the FSC served
EIN at the top of Schedule P. Also,
FSC makes pricing determinations
as commission agent for a related
check box 1c. Attach a tabular schedule
based on each transaction rather than an
to the partially completed Schedule P,
election to group transactions, check
reporting all information as if a separate
When Not To File
box 1a, box 1b, or box 1c depending on
Schedule P were filed for each
the FSC’s preferred reporting format.
transaction. Also see Format of tabular
Do not complete Schedule P (or an
a. Aggregate on Schedule P. If the
schedules on page 3.
alternate format) in the following three
FSC chooses to aggregate its
2. Group of transactions. The FSC’s
transactions on one or more Schedules
1. The section 482 method of transfer
related supplier may elect to group
P, check box 1a.
transactions by product or product line
pricing is used. If the 23% and 1.83%
• Aggregate on one Schedule P those
in making pricing determinations. The
methods (see the instructions for
transactions for which the same
grouping of transactions applies to all
Sections B and C on page 3) do not
administrative pricing method is applied,
transactions completed during the tax
apply to a sale or if the related supplier
does not choose to use them, the
provided all the transactions are
year for that product or product line. Do
not group sale and lease transactions.
transfer price for a sale by the related
included in the same product or product
supplier to the FSC is figured on the
line indicated in item A.
To make the election, complete one
basis of the sales price actually charged
• Aggregate on separate Schedules P
Schedule P, entering only the taxpayer’s
but is subject to section 482 and its
those transactions for which the same
name and EIN at the top of Schedule P.
regulations and to Temporary
pricing method is applied in each
Also, check box 2 of item B and attach a
Regulations section 1.925(a)-1T(a)(3)(ii).
tabular schedule to the partially
separate product line.
completed Schedule P, reporting all
2. The arm’s-length pricing method is
If a different pricing method is applied
information as if a separate Schedule P
used. If the transaction is with an
to some of the transactions in one or
were filed for each group of transactions
unrelated supplier, the FSC bases its
more of the separate product lines,
profit on the arm’s-length price.
(see Format of tabular schedules on
additional Schedules P must be filed.
3. Transactions are incomplete at the
Example. If the 23% of combined
Note: If a grouping basis is elected,
end of the year. If export property
taxable income method applies to
aggregate reporting is not permitted.
bought by the FSC from the related
transactions in three separate product
supplier during the tax year is unsold by
lines (as indicated in item A), the FSC
Attach Schedule P to Form 1120-FSC.
the end of the FSC’s tax year or the
would file three aggregate Schedules P.
Once the election is made, grouping
related supplier’s tax year in which the
redeterminations are permitted no later
However, if the FSC uses the 1.83% of
property was transferred, the 23% and
foreign trading gross receipts method for
than 1 year after the due date of the
1.83% methods cannot be used.
some of the transactions in one of the
FSC’s timely filed (including extensions)
Instead, the transfer price of the property
product lines, the FSC would file four
Form 1120-FSC. For details, see
bought by the FSC is the supplier’s cost
aggregate Schedules P.
Regulations section 1.925(a)-1(c)(8).
of goods sold for the property. See
Small FSC. If the FSC elected to be a
Temporary Regulations section
small FSC under section 922(b) and has
1.925(a)-1T(c)(5)(i)(C) for rules regarding
foreign trading gross receipts of $5
the transfer price of property resold
million or less for the tax year, the small
during the subsequent tax year.
FSC may file a separate Schedule P for
each group of transactions instead of
filing a tabular schedule.