The OECD’s new emphasis on aligning profits with value creation through the conclusion of the BEPS Action Plan has resulted in an ever-growing number of companies facing the challenge of preparing documentation that includes detailed value chain analyses and justifies transfer pricing (TP) policies.
On June 12, 2020, the United States (“U.S.”) Secretary of Treasury issued a statement (“Statement”) requesting that the Organization for Economic Co-operation and Development (“OECD”) pause international discussions designed to address the tax challenges facing the rapidly digitalized economy.
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.
On May 31, the Organization for Economic Co-operation and Development (“OECD”) issued a proposed approach to addressing challenges arising from the digitalization of the economy (the “Program of Work”). If it reaches consensus, the Program of Work could change “how taxing rights on income generated from cross-border activities in the digital age should be allocated among countries.”
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