Tax & Accounting Blog

BEPS Blog Series Part 2: Determining the best data source for BEPS compliance

BEPS Blog Series Part 2: Determining the best data source for BEPS compliance

Intelligence to help MNEs choose Our three-part blog series will offer insights on BEPS compliance and country-by-country reporting for transfer pricing professionals. If you missed part 1, you can read it here. When it comes to choosing a reporting basis for Country by Country (CbC) Reporting, the OECD has stated that multinational enterprises (MNEs) … Read More

Using technology to address the challenges of BEPS

Using technology to address the challenges of BEPS

Introducing ONESOURCE BEPS Action Manager. If you’re a corporate tax professional, you know about BEPS. You know that it is transforming the global tax landscape and will bring about unprecedented change to the way you report data to taxing authorities in countries across the globe. You know that country-by-country reporting will increase scrutiny and … Read More

BEPS Blog Series Part 1: BEPS is here… now what?

BEPS Blog Series Part 1: BEPS is here… now what?

Our three-part blog series will offer insights on BEPS compliance and understanding where to start when it comes to country-by-country reporting. For some time, the OECD’s Base Erosion and Profit Shifting (BEPS) guidelines have been a major topic of conversation for multinational enterprises (MNEs) and taxing authorities around the world. With numerous countries moving … Read More

Documenting Intercompany Interest Rates: Using Dealscan and Corporate Bond Data

Documenting Intercompany Interest Rates: Using Dealscan and Corporate Bond Data

A recent LinkedIn transfer pricing discussion provided an odd answer to a reasonable question about practitioners’ experiences with Dealscan. An attorney at a Big Four accounting firm wrote: I would be concerned that these reported prices do not fully reflect an arm’s length price because often times these banks will lend at a lower rate … Read More

Eaton, ASAT, and Section 6038A: A Call for Transfer Pricing Documentation

Eaton, ASAT, and Section 6038A: A Call for Transfer Pricing Documentation

Eaton Corp. v. Commissioner is heating up. Not only has the IRS invalidated its APA, but now it is trying to exclude certain evidence from the trial over the transfer pricing. According to a BNA story: “The IRS is seeking to prevent Eaton Corp. from presenting key testimony related to its business operations at a … Read More

Valuing Gilead’s Intangibles in Light of the Altera Aftermath

Valuing Gilead’s Intangibles in Light of the Altera Aftermath

Taxpayers are free to structure their intercompany transactions as they wish if the intercompany pricing is consistent with the arm’s length standard. Any evaluation of a transfer pricing issue depends on what the fundamental question is. In my view, the IRS lost Altera because it was asking the wrong question. In this blog, we will … Read More