United Nations Issues 2017 Transfer Pricing Manual

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

LB&I Launches Compliance Campaigns Targeting Transfer Pricing

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.

European Scrutiny Leading to Transfer Pricing Uncertainty

“[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.

Transfer Pricing Value Chain Analysis in 5 Steps

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.

UK Taxation of Multinationals in the Post-Brexit Environment

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.

Tax Efficiency in the Global Marketplace

Expansion into foreign markets is generally motivated by the perception that increased access to customers, vendors, natural resources, etc. will lead to increased shareholder returns.

“IRS Notice Chills Coca-Cola,” GlobalAtlanta

On September 30 GlobalAtlanta published an article by Ben Miller and Eunice Gonzalez, directors in Bennett Thrasher’s Transfer Pricing department, about Coca-Cola’s pending $3.3 billion tax liability, stemming from transfer pricing discrepancies.

BEPS Update for Small- and Medium-Sized Businesses

The Organization for Economic Cooperation and Development (OECD) has decided to exempt small- and medium-sized businesses (i.e. international groups that report total revenues of less than ?750 million) from the country-by-country (CbC) transfer pricing reporting requirement recommended in September of 2014 in its “Guidance on Transfer Pricing Documentation and Country-by-Country Reporting.”

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