(Part 1 of Series) – Originally published in TaxConnections The IRS guidance, Transfer Pricing Examination Process, Publication 5300 (TPEP), released in June 2018, is more relevant now than ever before. There is a broad consensus among transfer pricing and international tax practitioners that tax authorities around the globe will step up transfer pricing audit activity … Continue reading
I examine the intricate and evolving transfer pricing landscape in this insightful article. From the globally converging corporate income tax rates aimed at diminishing tax base erosion to the intense focus on intangibles in related legislation, the article provides a comprehensive overview of the key 2019 transfer pricing trends. The article also highlights the rising compliance and risk management burdens for multinational enterprises (MNEs) and the innovative use of technology to improve global transfer pricing processes. Finally, focusing on the U.S. Tax Cuts and Jobs Act (TCJA) of 2017 and its implications, the piece offers a detailed look at the changing dynamics of global tax competition. Learn more about how these shifts impact MNEs and their approach to managing transfer pricing risks. Continue reading
Attention, international tax managers and transfer pricing professionals: The IRS’s Transfer Pricing Examination Process (TPEP) is your insider’s guide to the IRS’s transfer pricing exams. This comprehensive guide, designed for IRS examiners, openly details the inner workings of their process. Learn how to proactively use this knowledge to strengthen your transfer pricing documentation, anticipate IRS inquiries, and avoid costly adjustments. Don’t be caught unprepared. This in-depth analysis of the TPEP will give you a significant advantage in ensuring your company’s transfer pricing practices meet IRS scrutiny. Discover the key takeaways, practical tips, and strategic insights that can make all the difference in the outcome of your next exam. Continue reading
Transfer Pricing NEWS The Transfer Pricing Operations (TPO) of the Large Business and International (LB&I) division of IRS released the 26-page Transfer Pricing Audit Roadmap to the public on February 14, 2014. The Transfer Pricing Audit Roadmap (“Roadmap”) provides audit procedures around an approximate 24-month audit timeline. The stated goals of the roadmap are to assist both … Continue reading
Markups on covered services and IRS scrutiny I am interested to know if anyone has experienced IRS scrutiny of services markups in instances where the services are “covered services” under Rev. Proc. 2007-13, but the taxpayer chooses to markup the services using a method (e.g., the cost of services plus method, or the CPM) that … Continue reading
TRANSFER PRICING INSIGHTS 