Tag Archives: transfer pricing exam

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 →

“SALT Transfer Pricing – What You Need to Know: Part 2”
Publications / SALT Transfer Pricing

“SALT Transfer Pricing – What You Need to Know: Part 2”

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This article discusses recent Multistate Tax Commission (MTC) State Intercompany Transactions Advisory Service (SITAS) Committee developments, state application of Tres. Reg. section 482 as evidenced in court cases, state transfer pricing amnesty programs, and measures taxpayers should consider to prepare for state transfer pricing audits. Continue reading →

“SALT Transfer Pricing – What You Need to Know: Part 1”
Publications / SALT Transfer Pricing

“SALT Transfer Pricing – What You Need to Know: Part 1”

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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 →

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 →

Impactful FYE Transfer Pricing Examination Preparedness Measures
Publications

Impactful FYE Transfer Pricing Examination Preparedness Measures

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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 →

How WTP Advisors Is Helping Corporate Tax Executives Handle Transfer Pricing Remotely 
Publications

How WTP Advisors Is Helping Corporate Tax Executives Handle Transfer Pricing Remotely 

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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 →

“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 →