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What does a case about fishing have to do with transfer pricing?
by Lisa Yashar, WTP Advisors ———- In the case Loper Bright Enterprises v. Raimondo, regarding a U.S. law governing marine fisheries management, the Supreme Court overturned the longstanding Chevron Doctrine. Its impact will be wide-reaching, providing opportunities to challenge agency interpretations of laws. This includes the treasury regulations under IRC § 482. What is the…
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Value Creation and the Lightbulb
Read more: Value Creation and the LightbulbBy Kash Mansori, WTP Advisors Posted: May 06, 2015 Last week the famous (infamous?) BEPS project released a discussion draft on the topic of how activities that create intangibles should be remunerated. According to existing guidelines and practice, when multiple entities work together to create an intangible, each entity is rewarded according to its share of the costs…
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Small Countries Taking Big Bites
Read more: Small Countries Taking Big BitesBy Kash Mansori, WTP Advisors Posted: April 30, 2015 Even relatively small countries can raise substantial tax and transfer pricing issues for the world’s largest multinationals. Take Denmark, for example. A couple of years ago the Danish tax authorities (“SKAT”) announced that they would be making a significant enforcement push with regard to transfer pricing. Recently…
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Transfer Pricing and the Regulatory Climate in India
Read more: Transfer Pricing and the Regulatory Climate in IndiaBy Kash Mansori, WTP Advisors Posted: March 06, 2015 When Barack Obama met with Prime Minister Narendra Modi in India last week, one of the items discussed was rather unusual for presidential summits: transfer pricing. But it seems that this attention from the highest levels of government may be having results. First of all, the…