We're tracking 7 live transfer pricing roles in Michigan.
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Transfer pricing in the context of Michigan primarily refers to the arm's-length pricing of transactions between related entities, as determined under federal (IRS Section 482) and international guidelines. While Michigan does not have its own specific transfer pricing rules, federal adjustments can impact the tax base for Michigan's corporate income tax (CIT).
Michigan imposes a 6% corporate income tax (MCL 206.653 and Chapter 2A of the Income Tax Act of 1967) on C corporations. This tax is based on federal taxable income, with specific Michigan adjustments. Therefore, any adjustments made by the IRS to intercompany transactions through federal transfer pricing audits directly flow through and can alter the federal taxable income from which Michigan's CIT base is derived. Michigan also has apportionment rules for multistate businesses (MCL 206.661 et seq.) where related-party transactions can implicitly influence the sales factor.