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Transfer Pricing

212 published works

  1. SALT Shaker

    COST 2025 Spring Conference and Audit Sessions

    By Eversheds Sutherland SALT

    Members of our SALT team are excited to present at COST’s 2025 Spring Conference and Audit Sessions, held in New Orleans, LA from April 28 to May 1. Sessions will cover a…

  2. Best Methods

    2024 APA Annual Report Shows Strong Year Despite Slight Decrease in Completions

    By Jason M. Osborn, Sonal Majmudar

    On March 27, 2025 the IRS’s Advance Pricing Mutual Agreement Program (“APMA” or the “Program”) released Announcement 2025-13 which provides APMA’s annual Advance Pricing Agreement (“APA”) report (the “Report”). Key…

  3. Best Methods

    A “Capacious” Arm’s Length Standard?

    By Anthony D. Pastore, Jason M. Osborn, Tyler M. Johnson

    In January, the IRS issued a generic legal advice memo on periodic adjustments and the arm’s length standard. Although the “GLAM” states that it merely “clarifies” and “updates” a prior…

  4. GT Amsterdam Law Blog

    OECD’s Amount B: Simplified Transfer Pricing for Routine Marketing and Distribution Activities

    By Wesley Boldewijn, James M. Maynor, Jr., Thomas de Booij

    On Feb. 19, 2024, the Organization for Economic Cooperation and Development (OECD) amended its transfer pricing guidelines to include “Amount B,” a standardized approach to determine the arm’s length remuneration…

  5. Allens Insights

    National Transfer Pricing Conference: Intragroup financing — More than just whether the price is right

    By Allens

    Toby Knight, Anna Sartori and Gidon Waller have published a paper examining the application of transfer pricing, the debt deduction creation rules (DDCR), the new thin capitalisation rules and the…

  6. Best Methods

    When Worlds Collide: Transfer Pricing and the CAMT

    By Anthony D. Pastore, Jenny A. Austin

    Last week, the US Treasury released long-awaited proposed regulations on the corporate alternative minimum tax or “CAMT.” In a press release, Treasury estimated “that around 100 of the largest and…

  7. Best Methods

    How Intercompany Agreements Can Mitigate Transfer Pricing Risk

    By Sonal Majmudar, Anthony D. Pastore

    Multinational groups constantly evolve, grow, and consolidate, and operational facts and circumstances always change. Say a growing company decides to expand internationally. It may choose to incorporate new foreign subsidiaries…

  8. Cooking with SALT

    Loper Bright Is Fuel for Future State Transfer Pricing Challenges

    By Katie Quinn, Chris Lutz

    Bloomberg Tax In Loper Bright Enterprises v. Raimondo, the US Supreme Court overturned the 40-year-old Chevron doctrine, which instructed courts to defer to any reasonable agency interpretation of an ambiguous law. This move has…

  9. Cooking with SALT

    Curious Developments in New Jersey Audits

    By Jeff Birdsong

    Great analysis by my colleague, Katie Quinn, on New Jersey's request for quotes for transfer pricing consultants. New Jersey transitioned to combined reporting, why do they anticipate a need for…

  10. Best Methods

    Private Transfer Pricing Disputes

    By Anthony D. Pastore, Sonal Majmudar, Jason M. Osborn

    In most transfer pricing disputes, the taxpayer squares off with the IRS or some other taxing authority, and the issue is the amount of tax due. But, in some cases,…