The 2022 SALT Transfer Pricing Quiz is anything but your run-of-the-mill test of knowledge. The Quiz, based on our January 2022 two-part Tax Notes State article, “SALT Transfer Pricing — What You Need to Know,” contains everything you need to know to swiftly grind out correct answers to the six multiple-choice questions and win a red, white, […]
Category Archives: Uncategorized
The UK enacts new rules requiring disclosure of tax treatments
The UK has enacted new rules requiring disclosure of tax treatments where the correctness of the position is uncertain. The rules are effectively a requirement that taxpayers must provide HMRC with a list of tax treatments that HMRC might wish to challenge. The rules are not specifically targeted at transfer pricing, but it seems likely that […]
Now is Not the Time to Ignore Transfer Pricing
By Scott Smaistrla COVID-19 necessitates a reassessment of the existing transfer pricing paradigms of Multinational Enterprises (MNEs). Supply chain disruptions and changes in consumer demand resulting from the COVID-19 pandemic and global recession are impacting virtually all major industries. These disruptions erode profits and will require MNEs to adjust transfer pricing approaches. MNEs also face […]
Apple, the EU, and Country by Country Reporting
Apple, the EU, and Country by Country Reporting The story of Apple Inc. and the European Commission is well known by now. Back in August of 2016 the EU’s Competition Commission announced their ruling that Ireland had given Apple an unfair sweetheart deal allowing it to pay less tax in Ireland than it should, and […]
Master File / Local File Transfer Pricing Documentation FAQs
Master File / Local File Transfer Pricing Documentation FAQs A client recently asked me to explain the “Master File / Local File” (“MF/LF”) system of transfer pricing documentation that is being adopted by an increasing number of countries. So I thought that there was no time like the present to put together a basic overview […]
BEPS Action 13 Update
BEPS Action 13 Update Earlier this year, our blog “Master File / Local File Transfer Pricing Documentation FAQs” provided an overview of what a Master File / Local File (MF/LF) system looks like along with practical considerations on implementing and maintaining the MF/LF system. As of today, our blog pops up at the top of […]
New Tax Legislation Consequences on U.S. Transfer Pricing and Intangibles
New Tax Legislation Consequences on U.S. Transfer Pricing and Intangibles The Tax Cuts and Jobs Act of 2017 (the Act) brought sweeping changes to the international tax landscape, including the transfer pricing arena. Intangible property is at the core of many of these changes. The impact of the new provisions generally furthers the trend of […]
Six Time-Tested TPEP Takeaways
While we have periodically written about the Transfer Pricing Examination Process, Publication 5300 (TPEP) and its predecessor, the Transfer Pricing Audit Roadmap, for this blog post we revisited the TPEP to determine how well this IRS guidance and our initial insights on it have withstood the test of time relative to our field-based transfer pricing (“TP”) experience […]