Topic
Transfer Pricing
212 published works
SALT Shaker
COST 2025 Spring Conference and Audit Sessions
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…
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…
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…
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…
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…
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…
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…
Cooking with SALT
Loper Bright Is Fuel for Future State Transfer Pricing Challenges
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…
Cooking with SALT
Curious Developments in New Jersey Audits
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…
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,…