Topic
Transfer Pricing
253 published works
Best Methods
The 2022 OECD Transfer Pricing Guidelines: Mostly An Update
On January 20, 2022, the OECD released the latest version of its OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations. The 2022 Transfer Pricing Guidelines update the 2017…
SALT Shaker
MTC SITAS Program addresses Eversheds Sutherland confidentiality concerns and pushes forward with 5 signatory states
By Jonathan Feldman, Eric Tresh
On February 2, the Multistate Tax Commission’s State Intercompany Transactions Advisory Service Committee (SITAS) held a public teleconference to address comments provided by Eversheds Sutherland and to schedule the first…
SALT Shaker
Washington finds B&O tax applies to transfer pricing payments
By Elizabeth Cha, Eversheds Sutherland SALT
The Washington Administrative Review and Hearings Division (the Division) of the Department of Revenue held that payments between affiliated entities could not be deducted from “gross income” subject to the…
Best Methods
Looking Forward: Predictions for 2022
By John T. Hildy, Elena B. Khripounova, Jason M. Osborn, Astrid Pieron, Anthony D. Pastore
In ancient Rome, a college of “augurs” would predict the future by observing the flight patterns of birds, examining the entrails of animal sacrifices, or interpreting natural phenomena. While perhaps…
SALT Insights
Louisiana Launches Unique State Transfer Pricing Initiative
By Stefi George
Joining Indiana and North Carolina, Louisiana last week became the third state to offer an alternative to the burdensome and expensive process of enduring a state transfer pricing audit. The…
Cooking with SALT
Louisiana Announces a New “Transfer Pricing Managed Audit Program”
By Andre Burvant, Bill Backstrom
The Louisiana Department of Revenue (the “Department”) released Revenue Information Bulletin No. 21-029 announcing the “Louisiana Transfer Pricing Managed Audit Program.” Beginning November 1, 2021, eligible corporations may request to…
Louisiana Law Blog
Louisiana Department of Revenue Announces A Transfer Pricing Managed Audit Program
By Jaye Calhoun, William Kolarik
On October 28, 2021, the Louisiana Department of Revenue (the “Department”) publicly announced a transfer pricing managed audit program in Revenue Information Bulletin No. 21-029 (October 26, 2021). Louisiana’s program…
SALT Shaker
Legal Alert: Louisiana Department of Revenue implements Managed Audit Program to address transfer pricing issues
The Louisiana Department of Revenue (the Department) issued Revenue Information Bulletin No. 21-029 (the Bulletin), inviting corporate income taxpayers to resolve intercompany transfer pricing issues via the Louisiana Transfer Pricing…
Best Methods
G20 Finance Ministers Endorse Landmark OECD/G20 Inclusive Framework Agreement: New Rules Likely to Put Added Pressure on Existing Transfer Pricing Rules
By Jenny A. Austin, Lucas Giardelli, Kenneth Klein, Michael Lebovitz, Jason M. Osborn, Tyler M. Johnson, Amit S. Neuman
On October 13, 2021, the G20 Finance Ministers and Central Bank Governors issued a Communiqué formally endorsing the political agreement reached by 136 countries of the OECD/G20 Inclusive Framework on…
Best Methods
Priority Guidance Plan Portends New Transfer Pricing Guidance
By Jason M. Osborn, Jenny A. Austin
On September 9, 2021, the Treasury Department and the Internal Revenue Service (“IRS”) issued its Priority Guidance Plan for 2021-2022. The Priority Guidance Plan gives the public a sense of…