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How to Capture Deductions in Puerto Rico for Payments to a Related Party

By Insights, Tax Planning & Consulting, Transfer Pricing

In an unanticipated response to taxpayer requests, the Puerto Rico Treasury Department (“PRTD”) has removed administrative hurdles to deduct 100 percent of expenses paid to related parties. Section 1033.17(a)(17) of the Puerto Rican Internal Revenue Code of 2011 (“PRIRC”) previously provided that taxpayers could deduct only 49 percent of the expenses paid to affiliates when computing net income for a Puerto Rican taxpayer.

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4 Key Takeaways from Ben Miller’s Presentation on Transfer Pricing

By Insights, Transfer Pricing

Bennett Thrasher Tax Partner Ben Miller recently spoke at a seminar at K&Y on transfer pricing. During the presentation, Miller shared the common mistakes made by multinational companies when pricing intercompany transactions and offered insight and simple steps companies can take to confirm their transfer pricing is appropriate and how to build an audit defense file.

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