Tag Archives: Multinational Enterprises

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 →

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 →