On June 29, 2018, the Internal Revenue Service (“IRS”) released Publication 5300 (06‑2018), Transfer Pricing Examination Process (“TPEP”), a 37-page document intended to guide IRS agents in the planning, execution and resolution of transfer pricing examinations (“TP Audits”).
Bennett Thrasher is proud to have assisted in creating an updated version of the DFK Transfer Pricing Handbook that was released recently. Ben Miller, BT Partner and DFK International Tax Committee Vice-Chair for Transfer Pricing, and the Bennett Thrasher TP team led the effort the update the Transfer Pricing Handbook, which involved collaboration with over 30 DFK member firms.
The Netherlands American Chamber of Commerce recently featured Ben Miller, Partner and leader of the firm’s Transfer Pricing practice, for their February Member Spotlight. Ben shared insight into Bennett Thrasher’s international practice and how the firm’s unique culture makes it different from competitors.
With some of the most dramatic changes in US taxation in over 30 years forthcoming, individuals
and businesses should take time to reassess their tax planning for 2017 and future years to
determine how they will be affected.
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.
Bennett Thrasher is proud to share that we have recently been recognized as a leading transfer pricing advisory firm by International Tax Review in its World 2018 guide.
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.
On April 7, 2017, the United Nations issued a revised version of transfer pricing manual that improves the alignment of the UN’s standards for transfer pricing with those offered by the OECD. Key updates related to value chain analysis and pricing controlled transactions involving services or intangible property
On January 31, 2017, the Internal Revenue Service (“IRS”) Large Business and International Division (“LB&I”) announced the identification and selection of 13 campaigns that will be the focus of the agency’s enforcement efforts.
“[The European Commission] is effectively proposing to replace Irish tax laws with a view of what the commission thinks the law should have been…Using the commission’s theory, every company in Ireland and across Europe is suddenly at risk of being subjected to taxes under laws that never existed.” Apple CEO Tim Cook’s reaction above epitomizes the sentiment among leaders of many US multinationals who are collectively conveying a tone of disapproval and worry after the European Commission’s latest ruling on state aid claws back approximately €13 billion in historical tax benefits previously granted by Irish Tax and Customs to Apple.
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.
Brexit’s bearing on United Kingdom (“UK”) tax policy is a common topic of discussion in the wake of the June 23rd, 2016 United Kingdom European Union membership referendum on the United Kingdom’s membership of the European Union (“EU”), which saw UK voters choosing to terminate its membership with the EU.