The IRS guidance, Transfer Pricing Examination Process, Publication 5300 (TPEP), released in June of 2018, is more relevant now than ever before. There is a broad consensus among transfer pricing and international tax practicioners that tax authorities around the globe will step up transfer pricing audit activity within the next year as a means to…

What We Are Doing to Help Corporate Tax Executives Handle Transfer Pricing Remotely It goes without saying that the COVID-19 pandemic is the major concern of nearly all multinational enterprises (MNEs) at the moment. Radical containment measures continue to be put in place by governments around the world in efforts to slow the spread of…

Many global trends in the transfer pricing landscape have emerged, including the growth of the digital economy, challenges to the arm’s length standard, increasing tax authority and taxpayer use of “big data” and discussions on the compensable value of data, and the increasing “popularity” of the profit split method. This article focuses on the following…

Numerous multinational enterprises (MNEs) have developed in-house capabilities and teams to manage their global transfer pricing. Many of our clients that run in-house transfer pricing teams note challenges such as: Limited resources to timely complete large numbers of documentation reports Inefficiencies with gathering and sharing information across departments and entities Difficulties organizing and tracking the…