As regulations change, the amount of global intercompany agreement data that is publicly available has increased dramatically. To keep up, have robust transfer pricing analyses, and defend future analyses, you’ll need to utilize it.
What is the best way for tax authorities and consultants to get company agreement data? You don’t need to rely on legal and tax departments for this data. It is publicly available, so you don’t need to settle for an information gap.
With the aggregated publicly-available M&A information available today, it is easy to ensure you have the same information as tax administrations.
With the wealth of publicly available intercompany transaction data, tax authorities no longer are at a disadvantage. Consultants must access that same wealth of data to ensure their transfer pricing analyses are defensible.
The final lesson we share that the Amazon v. IRS case demonstrates is the importance of understanding the royalty rates of agreements in comparison to your transaction before selecting on the final rate.
The CUT method of transfer pricing is a valuable intangible asset valuation approach. The court’s transfer pricing professionals in several recent cases use this methodology.
Transfer pricing professionals can learn crucial lessons from the recent Amazon v IRS case. Here we summarize the case, and lay the foundation for a blog series detailing those crucial lessons.
Look at the data your competitors are not! ktMINE brings together all the data publicly available in easily-searchable royalty rate and patent/assignment databases. Be your most effective with more data in less time.