The AICPA provided comments to the IRS on forthcoming proposed regulations that will include the Organisation for Economic Co-operation and Development’s (OECD’s) simplified and streamlined approach ...
Federico Vincenti and Carola Valente Della Rovere of Valente Associati GEB Partners/Crowe Valente analyse how intragroup ...
That “internal price” is called a transfer price. If you set those internal prices too high or too low, you can shift profits between places and taxes can end up being paid in the “wrong” place.
Internal Revenue Service sign with a traffic signal in the foreground indicating a red light. The IRS’ recent advice memorandum on periodic adjustments suggests that the agency may belatedly start ...
Opinion
Importance of a benchmarking database for effective implementation of transfer pricing regulations
In an increasingly globalised economy, transfer pricing has become a critical aspect of international taxation. ..
Captive service providers operate with limited risk and must be benchmarked differently from entrepreneurial companies. The analysis explains why TNMM and cost-plus returns are the appropriate ...
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