When the subject of transfer pricing arises, most finance and tax professionals think of international transfer pricing. Transfer pricing, however, can play an important role in state and local tax. Part 1 of the article examines: Three major reporting methods available to states under formulary-apportioned corporate tax reporting ◆ The effect of transfer pricing on different reporting methods ◆ The latest Multistate Tax Commission transfer pricing developments. Continue reading
U.S.-based MNEs face an inevitable IRS transfer pricing (“TP”) exam sooner rather than later. Fortunately, for U.S. companies in MNE groups, the IRS issued taxpayer guidance on exams in its Transfer Pricing Examination Process, Publication 5300 (TPEP). In this article, we view the TPEP at a high level and provide insights to help tax executives quickly make sense of the IRS’s TP guidance in preparation for 2022 TP documentation and exams in the years ahead. Continue reading
I coauthored “How WTP Advisors is Helping Corporate Tax Executives Handle Transfer Pricing Remotely,” which addresses common MNE in-house transfer pricing team pain points and brings a few of my recently developed software solutions to the table (e.g., TP Risk Assessment Model). This article was the concluding article in the September 2020 issue of the bilingual Americas-focused “AMÉRICA, Revista Regional” magazine, which contained articles written by firms in Argentina, Colombia, Costa Rica, Ecuador, and the United States. 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
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
TRANSFER PRICING INSIGHTS 