Tag Archives: arm’s length

Introducing the Profit Split Method: “To Apply or Not to Apply, this is a BEPS Question”
BEPS / Intangible Property / OECD / Profit Split Method / Publications / Transfer Pricing

Introducing the Profit Split Method: “To Apply or Not to Apply, this is a BEPS Question”

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The Profit Split Method (PSM) is gaining prominence in transfer pricing to ensure fair profit allocation among multinational enterprises. Learn when to apply the PSM based on unique and valuable contributions, highly integrated operations, or shared economically significant risks between controlled parties. Discover how the PSM aligns with the OECD’s BEPS initiative by considering the relative value contributed by each party to the transaction. Explore the origins, strengths, and practical applications of PSM. This article provides insights on using the PSM for arm’s-length pricing, tax planning, and defending against transfer pricing examinations. Continue reading →

SALT Transfer Pricing Quiz
Doug's TP Grab Bag / SALT Transfer Pricing

SALT Transfer Pricing Quiz

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Measure Your SALT & Transfer Pricing Know-How & Win with the 6-Question SALT TP Quiz! Alas, Quiz Prize eligibility closed on April 30, 2022. However, if you haven’t yet read the 2022 Tax Notes State article “SALT Transfer Pricing — What You Need to Know,” there is still time to request a copy of the article from within the Quiz, which we will keep open until 31 May 2022 for this purpose. WTP Advisors is administering the Quiz and all responses (score, name, etc.) will be kept in strict confidence unless, of course, you want us to call and tell your boss how smart you are! Continue reading →

“Global Trends in Transfer Pricing”
BEPS / Intangible Property / OECD / Publications / Risk Management (TP) / Technology (TP) / United States

“Global Trends in Transfer Pricing”

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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 →

IRS Transfer Pricing Audit Roadmap
Exams / Audits / Risk Management (TP) / Transfer Pricing / United States

IRS Transfer Pricing Audit Roadmap

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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 →

New Ukraine Transfer Pricing Rules
Transfer Pricing / Ukraine

New Ukraine Transfer Pricing Rules

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Prior to 2012, Ukraine had not been overly concerned about transfer pricing issues. But recently, in the era of fiscal deficits, the Ukrainian government has been more focused on implementing transfer pricing compliance practices in accordance with OECD member countries.  Transfer Pricing NEWS On December 4, 2012 the Parliament of Ukraine registered the draft bill … Continue reading →

Featured Article – Changes to Australia’s Transfer Pricing Rules
Transfer Pricing

Featured Article – Changes to Australia’s Transfer Pricing Rules

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Transfer Pricing NEWS: An exposure draft of legislation was released on November 22, 2012, “Tax Laws Amendment (Cross-Border Transfer Pricing) Bill 2013: Modernisation of transfer pricing rules—proposing changes to Australia’s domestic transfer pricing rules,” to introduce new Australian transfer pricing rules with significant self assessment and documentation requirements. The start date for these new rules … Continue reading →

The Queen v. GlaxoSmithKline Inc. – After two decades, still no resolution in Canada
Canada / Tax Court Cases / Transfer Pricing

The Queen v. GlaxoSmithKline Inc. – After two decades, still no resolution in Canada

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The Queen v. GlaxoSmithKline Inc. – After two decades, still no resolution in Canada Please click on the link for the News on the case, and read below for the Insights. CRA and the OECD The Supreme Court of Canada (SCC) rejected the CRA’s narrow “transaction-by-transaction” approach. What was the CRA thinking? Clearly, the Organisation for … Continue reading →

Pros and Cons of Safe Harbors, and Advice to Tax Authorities
OECD / Transfer Pricing

Pros and Cons of Safe Harbors, and Advice to Tax Authorities

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Why is it worth weighing pros and cons of safe harbors*? Because the OECD’s June 6, 2012 draft endorses safe harbors and presents three sample memoranda that countries may use to negotiate bilateral safe harbors. Also, most would say that the IRS has been successful with instituting safe harbors on interest rates for intercompany loans, and … Continue reading →