In February 2021, the Organisation for Economic Co-operation and Development (“OECD”) issued a handbook linked with the official roll-out of its International Compliance Assurance Programme (“ICAP”). ICAP was first introduced as a pilot in January 2018 (“ICAP 1.0”) as a
The headline news about the U.S. Tax Court’s decision on the value of Michael Jackson’s estate might have been a shock to some – or, perhaps, to many. The King of Pop’s inflation-adjusted earnings since his death in 2009, according
The Inland Revenue Authority of Singapore (“IRAS”) has issued transfer pricing guidance for centralized activities of multinational enterprise (“MNE”) groups in Singapore to assist taxpayers in analysing such activities between related parties and identifying factors that may affect transfer prices
Amount B aims to standardize the remuneration of related party distributors that perform baseline marketing and distribution activities in a manner that is aligned with the arm’s length principle. Its purpose is two-fold: First, Amount B is intended to simplify
In the U.S., transfer pricing benchmarking under the Comparable Profits Method (“CPM”) or Transactional Net Margin Method (“TNMM”) depends on the availability of public company financial data. In recent years, the decreasing number of U.S. listed and non-exchange traded companies
Benchmarking—the process of screening, selecting, and analyzing comparable companies—is time consuming. Analysts can spend innumerable hours every year preparing transfer pricing documentation, with a substantial portion of that time dedicated to benchmarking. Even with improvements in the quality of databases
On March 23, 2021, the United States’ Advance Pricing and Mutual Agreement Program (“APMA Program”) released its 2020 annual report (“2020 Annual Report”) to the public concerning advance pricing agreements (“APAs”). COVID-19 has caused unprecedented disruptions to taxpayers and tax
Overview. As discussed in prior blog posts, Amount A is a proposed new taxing right over a share of residual profit of MNE groups that fall within its defined scope. The calculation and allocation of Amount A will be determined
Consider the following hypothetical: Researchers at a US-parented drug company develop an artificial intelligence (or “AI”) system that can identify new therapeutic targets with minimal human intervention. The drug company sells the system to its foreign affiliate in a lower-tax
As discussed in prior blog posts, Amount A is a proposed new taxing right over a share of the residual profit of MNE groups that fall within its defined scope. The tax base is therefore determined on the basis of
