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Tariffs and Transfer Pricing: Managing Global Intangible Property in a Dynamic Trade Environment
by Michael Bredahl, WTP Advisors ———- As global trade shifts in response to tariffs being employed as a key tool of economic policy, U.S. multinationals should urgently reassess their legacy transfer pricing strategies, particularly regarding intangible property (IP). The structure and location of IP ownership can either mitigate or exacerbate tariff exposure, fast becoming a…
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The Economist Falls for Formulary Apportionment
Read more: The Economist Falls for Formulary ApportionmentBy Kash Mansori, WTP Advisors Posted: February 04, 2016 Last week The Economist devoted one of its leaders to the topic of transfer pricing. From the January 30th issue: Going after Google Britain’s tax men struck a poor deal. But the real problem lies with flawed corporate-tax rules. It was meant to win plaudits for…
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Dutch State Aid Starbucks update
Read more: Dutch State Aid Starbucks updateBy Richard Slimmen of Quantera Global Posted: December 02, 2015 Originally Posted by Quantera Global On 21 October 2015 the European Commission declared that Luxembourg and the Netherlands have granted selective tax advantages to Fiat and Starbucks, respectively. These practices are illegal under EU State Aid rules. The Dutch government has responded last Friday (27 November…
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What the Focus on “Value Creation” Misses
Read more: What the Focus on “Value Creation” MissesBy Guy Sanschagrin Posted: November 12, 2015 In his blog post: BEPS – What It All Means, my esteemed colleague Kash Mansori explained that a key to a defensible transfer pricing policy is to align the allocation of taxable income among entities in multinational supply chains with “value creation”. And while this concept introduced under BEPS seems sensible in…