Posts Tagged ‘Transfer Pricing’
Understanding the Contrast: IRS Rules on Allocation of Intangible Property Income vs. OECD DEMPE Rules
At a glance The full Story With the rise of digitalization in the global economy, the complexities of cross-border transactions and multinational corporations have prompted governments to rethink the allocation of income generated from intangible property. These intangibles, such as patents, copyrights, trademarks, and intellectual property, often transcend physical borders, posing significant challenges in terms…
Read MoreNew IRS Enforcement Initiative Targeting Inbound Distributors’ Transfer Pricing
At a glance Background: The IRS has become increasingly concerned that foreign-owned companies are not accurately reporting their taxable income according to U.S. transfer pricing regulations under Section 482 of the Internal Revenue Code. In doing so, companies can shift profits to jurisdictions outside the U.S., potentially taking advantage of lower tax rates or other…
Read MoreAre You Overpaying on Duties for Imported Goods?
At a glance The full story: In recent decades, the U.S. Customs and Border Protection’s (CBP) First Sale Rule has gained traction as a strategic way for importers to substantially reduce the customs duties paid on imported goods. The First Sale Rule provides importers in multi-tier transactions a viable alternative to the more commonly used…
Read MoreNews Alert: Recent Development in Transfer Pricing Legislation in UK, Brazil, and Canada
At a glance The full story: In a significant move that impacts global business landscapes, the United Kingdom, Brazil, and Canada have recently introduced new transfer pricing regulations. These changes are poised to reshape the way multinational companies conduct cross-border transactions, emphasizing transparency, fairness, and stricter compliance with the arm’s length principle. United Kingdom: The…
Read MoreTransfer Pricing and Customs Valuations: Finding Peace in a Trade War
At a glance The full story: As the largest global trading nation, the U.S. has imposed various tariff measures in recent years, such as the Section 301 “China” tariffs and the Section 232 “Steel and Aluminum” tariffs, signaling a new era of the trade war. The introduction of these tariffs has placed financial burdens on…
Read MoreTransfer Pricing Overview
Case Study: Tax Savings with Transfer Pricing & Compliance Solutions
About the Client: Aprio engaged an international supply chain logistics company that specializes in the warehousing space and is based in New Zealand. Since its inception, the company has grown to become one of the largest third-party logistics organizations in New Zealand, working with both B2B and B2C customers to provide supply chain consulting and…
Read MoreThe Inflation Reduction Act and Transfer Pricing: Key Facts You Should Know
At a glance The main takeaway: A portion of the IRS’s funding from the Inflation Reduction Act will be directed toward enforcement actions on corporations and high-net-worth individuals. Impact on your business: This increase in enforcement funding will most likely trigger more audits of transfer pricing arrangements, which means multinational businesses need to prepare proactively.…
Read MoreCase Study: Optimizing Tax Efficiency and Restaurant Operations Using Transfer Pricing
About the Client: Aprio partnered with a successful restaurant group based in New York City. With its collection of fine dining restaurants in the heart of Manhattan, the group aims to provide patrons with unique dining experiences by celebrating tradition, offering authentic cuisine and infusing the atmosphere with lively local culture. The Challenge: The client’s…
Read MoreCase Study: Using Transfer Pricing to Simplify Complex Intercompany Charges
About the Client: Aprio engaged an international security solutions provider that specializes in designing, installing, managing and harmonizing physical security systems across the globe. With a team of more than 270 trained and experienced industry professionals, the company has successfully executed thousands of security projects for some of the world’s most demanding and growth-oriented organizations.…
Read More