{"id":263,"date":"2022-04-14T14:10:08","date_gmt":"2022-04-14T14:10:08","guid":{"rendered":"https:\/\/wtpadvisors.com\/?p=263"},"modified":"2024-02-12T18:00:51","modified_gmt":"2024-02-12T18:00:51","slug":"take-a-break-from-your-daily-grind-with-our-six-question-salt-transfer-pricing-quiz","status":"publish","type":"post","link":"https:\/\/wtpadvisors.com\/tp-blog\/take-a-break-from-your-daily-grind-with-our-six-question-salt-transfer-pricing-quiz\/","title":{"rendered":"Take A Break from Your Daily Grind with our Six-Question SALT Transfer Pricing Quiz!"},"content":{"rendered":"

by Doug Schwerdt, WTP Advisors<\/p>\n

The\u00a02022 SALT Transfer Pricing Quiz<\/strong>\u00a0is anything but your run-of-the-mill test of knowledge. The Quiz, based on our January 2022 two-part Tax Notes State article, \u201cSALT Transfer Pricing \u2014 What You Need to Know,\u201d contains everything you need to know to swiftly grind out correct answers to the six multiple-choice questions and win a red, white, or blue Peugeot SALT mill or Amazon gift card. Read carefully; this blog post is also your \u201cCliffs Notes\u201d to a few answers\u2026<\/p>\n

If you yearn to start the Quiz now, then click the red launch button below to go directly to the Quiz! (Otherwise, the hyperlink will still be here after you finish reading this blog post\u00a0\ud83d\ude42)<\/p>\n

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Press to LAUNCH the SALT TP Quiz!\u00a0<\/strong>\ud83c\udf93<\/a><\/div>\n<\/div>\n
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Why is domestic transfer pricing important in the U.S.? Many of our SALT practitioner readers have been keen on reading the answer to this question in \u201cSALT Transfer Pricing \u2014 What You Need to Know:\u00a0Part 1<\/strong><\/a>,\u201d which was published on January 24. Meanwhile, many internationally focused transfer pricing readers have benefitted from reading about the three major formulary-apportioned corporate tax reporting methods (i.e., separate reporting, combined reporting, and consolidated reporting), and several have been amazed that they too can perform state apportionments of corporate income under different methods based on sales, property, and payroll! In Part 1, we also cover the most important Multistate Tax Commission (MTC) State Intercompany Transactions Advisory Service (SITAS) Committee developments in 2021. For more detail on Part 1, see our last transfer pricing blog post with\u00a0Six \u201cSALTy\u201d Transfer Pricing Facts<\/a><\/em>.<\/p>\n

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In \u201cSALT Transfer Pricing \u2014 What You Need to Know:\u00a0Part 2<\/strong><\/a>\u201d we focus on the following three areas:<\/p>\n

State Court Cases Supporting Taxpayer\u2019s Transfer Pricing Studies<\/h2>\n

We start Part 2 by examining three tax court cases as examples of how different states have applied the U.S. Treasury Regulations under IRC Section 482 to evaluate the appropriateness of taxpayer interstate transfer pricing. In all three cases, the court ruled in support of taxpayer Section 482-compliant transfer pricing studies as providing evidence of arm\u2019s length intercompany transactions.<\/p>\n

APAs and Voluntary Amnesty Programs<\/h2>\n

States have recently strengthened their transfer pricing enforcement capabilities and are focusing efforts on promptly and cost-effectively resolving transfer pricing cases. The two main avenues states are following to resolve transfer pricing cases more effectively are advance pricing agreements (APAs) and programs that promote voluntary disclosure in exchange for penalty amnesty.<\/p>\n

How to Prepare for State Transfer Pricing Audits<\/h2>\n

We explain how to prepare for U.S. domestic transfer pricing audits. Measures include Section 482-compliant transfer pricing studies to demonstrate how related-party transactions are consistent with the arm\u2019s-length standard, weighing the pros and cons of APAs and voluntary disclosure amnesty programs, and preparing for specific points that often need to be supportably addressed by a company during a SALT audit involving transfer pricing (e.g., background and business reasons for the intercompany transactions, total profits or losses associated with each controlled transaction and each controlled party\u2019s share of the total profits or losses, etc.).<\/p>\n

With subscription-worthy content like the steps we provide on how to prepare for state transfer pricing audits, we think you\u2019ll agree that winning one of the renowned Peugeot SALT mill prizes is just an extra dash of flavor on your domestic transfer pricing preparedness. It\u2019s our way of saying thank you for reading. The true prize is\u00a0state-by-state freedom from transfer pricing adjustments and penalties<\/em>\u00a0and the\u00a0nightly SALT transfer pricing peace of mind<\/em>\u00a0that surely makes every supper more savory.<\/p>\n

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Would you like to receive a copy of the Tax Notes State \u201cSALT Transfer Pricing \u2014 What You Need to Know\u201d article?<\/strong><\/p>\n