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4 Transfer Pricing Implications from the Coronavirus
Posted by Chrissy Hammond on Wed, Mar 25, 2020 @ 02:58 PM

The COVID-19 virus pandemic continues to evolve, causing substantial shifts in financial markets and the macro economy, which brings direct implications for multinational enterprises (MNEs). As governments enact new restrictions in an effort to protect public health, MNEs will most likely face disruptions to their supply chains and challenges related to moving personnel across borders.

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Topics: transfer pricing, COVID19, Coronavirus, multinational enterprises

Multi-National Enterprises Need to Reevaluate Transfer Pricing Documentation
Posted by David Mula on Thu, Jun 18, 2015 @ 10:10 AM

In 2013, the Organisation for Economic Co-operation and Development (OECD) and the G20 Countries developed a 15-Point Action Plan in an effort to address Base Erosion and Profit Shifting (BEPS). The OECD and G20 Countries worked together on this Action Plan in an attempt to address concerns about aggressive tax planning by multi-national enterprises (MNE) to reduce their tax liabilities by shifting profits to low or no tax jurisdictions. Part of the Action Plan called for changing transfer pricing documentation to enhance transparency, certainty, and predictability for tax administrators and taxpayers. The United Kingdom and Australia are two examples of countries that have quickly adopted the transfer pricing documentation guidance. MNEs need to reevaluate their transfer pricing documentation to ensure that it meets the standards set forth by the Action Plan, while considering the nuances of the rules in the various countries in which they do business.

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Topics: transfer pricing, David Mula

Transfer Pricing Roadmap Gives Insight on Examination Issues
Posted by Claudia Mullen on Thu, Jun 19, 2014 @ 09:14 AM

In February 2014, the IRS Transfer Pricing Operations (TPO) team issued a Transfer Pricing Audit Roadmap. The roadmap is intended to assist IRS examination teams with identifying and auditing transfer pricing issues. The creation of this roadmap reflects the Service's increased focus on transfer pricing matters. The roadmap also gives us insight into which transfer pricing issues will be scrutinized more closely and what kind of documentation the IRS expects to be in place to support the taxpayer's position.

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Topics: Claudia Mullen, Transfer Pricing Audit Roadmap, transfer pricing

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