Ben Miller

Multinational firms have historically sought to establish transfer pricing policies that comply with the local transfer pricing rules and regulations while also helping to facilitate strategic objectives that drive profitability. 

News stories exposing many large multinational enterprises (“MNEs”) like Apple, Starbucks, Google, etc. for utilizing tax avoidance schemes are motivating governments and tax authorities around the world to quickly ramp up enforcement of tax rules intended to mitigate the ability for MNEs to implement such schemes.

The Organization for Economic Cooperation and Development’s (“OECD’s”) Base Erosion and Profit Sharing (“BEPS”) has resulted in the worldwide implementation of more stringent requirements for justifying transfer pricing policies and preparing appropriate transfer pricing documentation.