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Decoding India’s New Transfer Pricing Documentation Requirements

As tax professionals head towards the end of the calendar year, keeping abreast of an ever changing dynamic of rules, regulations and reporting requirements continues to be a daunting challenge that promises to continue in 2018 and beyond.  Between looming tax reform in the United States, rules impacting how the digital economy is taxed, and [...]

By | 2017-12-21T17:18:46+00:00 December 21st, 2017|

2017 Transfer Pricing Deadlines

As we approach the end of the year, here are a couple deadlines to be aware of: Country-by-Country Reporting Notification For U.S. ultimate parent entities of multinational enterprises (“MNEs”) that are filing Internal Revenue Service Form 8975 and Schedules A (Form 8975) (“Country-by-Country Report”) for the year ending December 31, 2017, the Country-by-Country Report will [...]

By | 2017-12-14T19:37:34+00:00 December 14th, 2017|

Updated Guidance on Implementation of Country-by-Country Reporting

The Organisation for Economic Co-operation and Development (“OECD”) issued updated guidance (“Guidance”) on the implementation of country-by-country reporting (“CbC”) in September 2017.  The Guidance adds certain items to the version issued in July 2017.  The new items are: DEFINITION OF REVENUES. The Guidance provides that “all revenue, gains, income, or other inflows shown in the financial [...]

By | 2017-11-13T01:06:58+00:00 October 16th, 2017|

Things to Watch for in Country-by-Country Reporting

Country-by-country reporting (“CbC”) requires certain information and in forms that might not be immediately apparent.  Multinational enterprise (“MNE”) groups subject to CbC reporting should be aware of those requirements.  They include: Revenues; Aggregation; Withholding taxes; and Income tax paid. REVENUES.  For purposes of CbC reporting, revenues include more than just net sales.  The Internal Revenue Service [...]

By | 2017-11-13T01:07:17+00:00 October 2nd, 2017|

Proposed Template for Advance Pricing Agreements

The Advance Pricing and Mutual Agreement Program (“APMA”) of the Internal Revenue Service (“IRS”) has provided for public discussion, a draft updated template for use in drafting advance pricing agreements (“APAs”).  It is designed to “systemize how taxpayers propose terms for their APAs and standardize language used in executed APAs” as well as “improve efficiency [...]

By | 2017-11-13T01:07:25+00:00 September 29th, 2017|

Allocation of Risk When Control is Shared Among Different Legal Entities

The new OECD Guidance on transfer pricing emphasizes the role of control and decision-making, and essentially states that risk allocations will only be respected if the legal entity that is bearing the risk also controls that risk.  One of the key questions in this regard is what happens when several different legal entities control risk?  [...]

By | 2017-11-13T01:07:39+00:00 September 28th, 2017|