Topic
Transfer Pricing
256 published works
Best Methods
The Vanishing U.S. Comparable
By Elena B. Khripounova, Jason M. Osborn, Anthony D. Pastore
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,…
Best Methods
Artificial Intelligence for Benchmarking: The Wave of the Future
By Elena B. Khripounova, John T. Hildy, Anthony D. Pastore
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…
Best Methods
APMA to COVID-19: Don’t Stop Me Now
By Jason M. Osborn, Tyler M. Johnson, Samantha I. Bear
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…
China Law Insight
内关联交易豁免原则的适用
By King & Wood
在转让定价领域，境内关联企业之间发生的交易简称为“内关联交易”，实践中有些企业认为内关联交易不涉及利润的跨境流动，所以其转让定价问题不是税务机关关注的事项。同时,基于《特别纳税调查调整及相互协商程序管理办法》（国家税务总局公告2017年第6号，以下简称“6号公告”）豁免原则的规定，企业通常认为内关联交易的定价政策被税务机关转让定价调查调整的风险相对较小，相较于跨境关联交易而言，集团可以较为自如地在境内关联企业间转移利润。
SALT Shaker
Legal Alert: MTC SITAS Committee meeting – transfer pricing group holds first meeting since 2016
On March 23, the State Intercompany Transactions Advisory Service (SITAS) Committee of the Multistate Tax Commission (MTC) met via videoconference for its first meeting since November of 2016. During the…
Best Methods
Transfer Pricing for AI-Generated Intellectual Property
By Richard M. Assmus, Jason M. Osborn, Anthony D. Pastore
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…
Israel Global Gateway
Noteworthy rule changes impacting transfer pricing documentation requirements for fiscal year 2020 and beyond
By Israel Group
2020 has been an unprecedented year filled with many uncertainties. In the transfer pricing world, the OECD has been busy addressing transfer pricing implications of the coronavirus disease 2019 (COVID-19) and Digital Services Taxation,…
China Law Blog
China Transfer Pricing Laws: Because They Matter
By Dan Harris
If you had told me ten years ago that I would one day be writing on transfer pricing, I would never have believed it. Heck, if you had told me…
Best Methods
The Mutual Agreement Procedure (“MAP”): Advantages and Potential Pitfalls for Resolution of Double Tax Issues
By Jason M. Osborn, William G. McGarrity, May Y. Chow
The Mutual Agreement Procedure (“MAP”) is a useful dispute resolution mechanism for multinational companies facing a transfer pricing or other assessment resulting in double tax, whether in the U.S. or…
Disputing Tax
Upcoming & Noteworthy Tax Controversy Events
Please Join Us! ABA Virtual 21st Annual U.S. and Europe Tax Practice Trends Conference: Kat Gregor is co-chair of the ABA's Virtual 21st Annual U.S. and Europe Tax Practice Trends…