U.S. Reaction to OECD Transfer Pricing Recommendations

This past September, the Organization for Economic Cooperation and Development (OECD) published a draft version of its official recommendations for transfer pricing documentation and reporting, “Guidance on Transfer Pricing Documentation and Country-by-Country Reporting” (the Recommendations Draft).

Transfer Pricing Health Check

Does your company need a Transfer Pricing health check? Do you have a thorough understanding of your company’s transfer pricing risk? Understanding and quantifying your risk is a critical step in responsibly managing it.

Using F Reorganization Strategically in Mergers & Acquisitions Transactions

Many practitioners are familiar with the benefit of using disregarded entities (DEs) or Single Member Limited Liability Companies (SMLLCs) in structuring merger & acquisition transactions. However, advisors should also consider the advantages of using F-reorganizations to solve certain problems that can be encountered when forming a SMLLC.

Bennett Thrasher Transfer Pricing Update: India Releases Draft Safe Harbor Rules

For transfer pricing purposes, “safe harbors” are profit margins or prices considered acceptable by a certain tax jurisdiction for low-risk, cross-border intercompany transactions. Tax authorities institute safe harbors as a means to decrease time and resources spent in investigations and disputes over routine transactions.

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