Posts Tagged ‘Transfer Pricing’
2022 – The Year of Waiting for US Transfer Pricing
By: Carl Budenski At a glance The main takeaway: There are several major and potentially game-changing transfer pricing developments in the pipeline that multinational businesses should be aware of. Impact on your business: Some of the biggest updates on the horizon include four high-priority projects helmed by the Treasury and IRS, stalled litigation cases and…
Read MoreHow to Develop the Right Transfer Pricing Strategy for Your Business
At a glance Take action before you do business abroad: From startups interested in expanding internationally to established multinational enterprises, transfer pricing planning is a necessity for every business with cross-border transactions. Impact on your business: Not only can transfer pricing planning help you meet the IRS’s regulatory requirements, but it can also help you…
Read MoreTransfer Pricing and COVID-19 – Time to Re-Examine Your Policy
At a Glance Multinational Companies Beware: Economic impacts from COVID-19 may require a new transfer pricing policy to avoid future penalties. Impact on Your Business: Companies using profits-based transfer pricing methods will be affected the most. Next Steps: You need to take immediate action to determine if your current transfer pricing is defensible or if you need a…
Read MoreUtah Supreme Court Upholds Taxpayer’s Transfer Pricing in Related-Party Transaction
States may have the authority to adjust related-party payments, but only after determining that the transactions are not at arm’s length under federal transfer pricing principles. Transfer pricing issues don’t just arise in international transactions; they arise across state lines as well. Transfer pricing rules give taxing jurisdictions the ability to claw back transactions with…
Read MoreTransfer Pricing Considerations: How to Plan and Win on International Taxes
As you be gin to audit your financial documentation, you should keep various transfer pricing considerations in mind.
Read MoreTransfer Pricing: Re-Evaluating Profit Splits
IRS Issues New Transfer Pricing Audit Roadmap
The IRS released a Transfer Pricing Audit Roadmap on February 18, 2014. The Roadmap, which was issued through the IRS Transfer Pricing Operations of the Large Business and International (LB&I) division, was developed to provide audit techniques and tools for transfer pricing examinations. The Roadmap is designed as a comprehensive toolkit based on an audit…
Read MoreTransfer Pricing – General Principles, Penalties and Contemporaneous Documentation
General Principles – Transfer pricing is relevant for U.S. companies with foreign subsidiaries or foreign parent companies that engage in certain intercompany transactions. U.S. transfer pricing rules require that intercompany pricing between a U.S. company and a foreign affiliate must be based on an ‘arm’s length’ price that would be charged in a similar transaction…
Read MoreKnow Transfer Pricing to Avoid IRS Difficulty
By Mitchell Kopelman, partner-in-charge of Tax, and Yelena Epova, partner-in-charge of International Services If your company plans to expand operations in the United States or into other countries, then you need to know about transfer pricing. A transfer price is the price at which U.S. and non-U.S. related companies buy and sell goods and services…
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