Tag Archives: arm's length standard

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 →

Six Salaciously SALTy Transfer Pricing Facts You’ll Want to Read More About!
Transfer Pricing

Six Salaciously SALTy Transfer Pricing Facts You’ll Want to Read More About!

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On 24 January 2022, Tax Notes State published SALT Transfer Pricing — What You Need to Know: Part 1. I realize many readers of this blog have an insatiable hunger for all things transfer pricing (with SALT or without). To whet your appetite, here are six salaciously SALTy transfer pricing facts you’ll be longing to read more about in my full coauthored article… Enjoy! 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 →

Review of and Insights on the IRS Transfer Pricing Examination Process
Exams / Audits / Publications / Transfer Pricing / United States

Review of and Insights on the IRS Transfer Pricing Examination Process

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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 →