Transfer Pricing Blog

Blogs November 21, 2019 How Tariffs Impact Transfer Pricing

The need for multinationals to understand how tariffs impact transfer pricing. Proper documentation, such as an advanced pricing agreement, can facilitate an improved tax position and regulatory compliance.

Blogs February 16, 2018 Transfer Pricing Roadmap Released

The IRS intends the Transfer Pricing Audit Roadmap to be a practical and user-friendly toolkit taxpayers can reference around a notional 24-month audit timeline. Since every transfer pricing case is unique, judgment needs to be exercised on how to be…

Blogs June 15, 2016 Important Considerations for Transfer Pricing and Customs Valuations

The CBP acknowledges that transfer pricing studies and other transfer pricing-related documentation can act as a starting point for pricing used in a customs context. However, simply relying on tax-related documentation is becoming less acceptable.

Blogs June 06, 2016 Transfer Pricing at the State Level

The Multi-State Tax Commission has advocated for applying transfer pricing documentation to state taxation. The MTC proposed a plan for state tax adoption of transfer pricing concepts well-traversed in the international tax area.

Blogs May 31, 2016 Kraft Foods Global Inc. v. Director, Division of Taxation

The New Jersey Tax Court’s recent decision on Kraft Foods Global Inc. v. Director, Division of Taxation to disallow interest payment deductions by a Kraft Foods Inc. subsidiary is a signal that transfer pricing in state taxation is gaining momentum.

Blogs May 23, 2016 IRS Moving Transfer Pricing to the Front Burner

International tax took center stage last week when the temporary Treasury regulations on tax inversions put an end to the proposed merger between Pfizer and Allergen.