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Six Time-Tested TPEP Takeaways

Posted on February 25th, 2021

This blog post is a companion to our article “Impactful FYE Transfer Pricing Examination Preparedness Measures” in the December 2020 TGS Global AMÉRICA Regional Magazine. Following are six TPEP takeaways that we have found to be even more important today than a few years ago.

Now is Not the Time to Ignore Transfer Pricing

Posted on April 29th, 2020

COVID-19 necessitates a reassessment of the existing transfer pricing paradigms of Multinational Enterprises (MNEs). Supply chain disruptions and changes in consumer demand resulting from the COVID-19 pandemic and global recession are impacting virtually all major industries. These disruptions erode profits and will require MNEs to adjust transfer pricing approaches. MNEs also face challenges such as government restrictions on travel and enabling personnel to work remotely.

What We Are Doing to Help Corporate Tax Executives Handle Transfer Pricing Remotely

Posted on March 30th, 2020

It goes without saying that the COVID-19 pandemic is the major concern of nearly all multinational enterprises (MNEs) at the moment. Radical containment measures continue to be put in place by governments around the world in efforts to slow the spread of the virus. Many of these measures center on the concept of ‘social distancing’ and have included closing businesses and organizations, cancelling events, prohibiting international and domestic travel, and quarantining cities and even regions. COVID-19 containment measures have disrupted business as usual, from manufacturing plant shutdowns to creating information inefficiencies and collaboration challenges at MNE headquarters and across global entities. These business disruptions create challenges for effectively managing transfer pricing information and workflows.

What to Expect When You’re Expecting… A Transfer Pricing Examination

Posted on May 1st, 2019

Transfer pricing examinations can be unpleasant experiences for taxpayers. Chances are, an international business in the U.S. – whether it is headquartered in the U.S., or a subsidiary of a foreign parent – is going to have its transfer pricing examined by the IRS or another tax authority.

New Tax Legislation Consequences on U.S. Transfer Pricing and Intangibles

Posted on January 17th, 2018

The Tax Cuts and Jobs Act of 2017 (the Act) brought sweeping changes to the international tax landscape, including the transfer pricing arena. Intangible property is at the core of many of these changes. The impact of the new provisions generally furthers the trend of transfer pricing becoming more prescriptive, placing additional strain on and creating potential contradictions with the arm’s length standard, and may have the unintended consequence of creating double-taxation for U.S. Multinationals (MNCs) – situations in which U.S. MNCs may be taxed more than once on the same income. So, while the Act lowered the headline tax rate to 21 percent, it also broadened the base that will be taxed, with the result that the Act’s effect on each company’s tax bill will be determined by the company’s specific facts and circumstances.

BEPS Action 13 Update

Posted on November 14th, 2017

Earlier this year, our blog “Master File / Local File Transfer Pricing Documentation FAQs” provided an overview of what a Master File / Local File (MF/LF) system looks like along with practical considerations on implementing and maintaining the MF/LF system. As of today, our blog pops up at the top of Google search results for the terms “Transfer Pricing Master File” – ahead of content published by the OECD. This tells us that many found our content unique and helpful. Given your level of interest, we thought we’d provide an update on new developments associated with the implementation of Action 13 across the world.

Master File / Local File Transfer Pricing Documentation FAQs

Posted on March 23rd, 2017

A client recently asked me to explain the “Master File / Local File” (“MF/LF”) system of transfer pricing documentation that is being adopted by an increasing number of countries. So I thought that there was no time like the present to put together a basic overview of this increasingly common format for assembling and organizing an MNE’s transfer pricing reports.

Apple, the EU, and Country by Country Reporting

Posted on February 1st, 2017

The story of Apple Inc. and the European Commission is well known by now. Back in August of 2016 the EU’s Competition Commission announced their ruling that Ireland had given Apple an unfair sweetheart deal allowing it to pay less tax in Ireland than it should, and ordered Ireland to send Apple a €13 bn bill for back taxes and interest covering the period 2003-14. For their part, Ireland and Apple both have said that they intend to fight the ruling. The legal battle is likely to go on for years, and may well end up at the highest court in the EU, the European Court of Justice.

2016 Blog Archive

Posted on December 31st, 2016
2016 Blog Archive

Country by Country Reporting Update What to Expect When You’re Expecting… An Audit The Economist Falls for Formulary Apportionment

2015 Blog Archive

Posted on December 31st, 2015
2015 Blog Archive

Dutch State Aid: Starbucks update What the Focus on “Value Creation” Misses BEPS – What It All Means The Quantera Global Connection BEPS in Verse It’s All About the Data Australia First! Value Creation and the Lightbulb Small Countries Taking Big Bites Transfer Pricing and the Regulatory Climate in India The EU Commission’s Problematic Reasoning… Read More »

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