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).
The German American Chamber of Commerce South News published an article written by Ben Miller, Director and Jessica Oeller, Staff, at Bennett Thrasher.
Bloomberg BNA Transfer Pricing Report turned to Ben Miller, Director in the Bennett Thrasher transfer pricing practice, for expert commentary in its article, “Arm’s-Length Panel Mulls Next Steps For State-Level Transfer Pricing Service.”
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.
On January 30, 2014 the Organization for Economic Co-operation and Development (the “OECD”) published the Discussion Draft on Transfer Pricing Documentation and Country-by-Country Reporting (the “Discussion Draft”).
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.
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.