On July 24, 2018, the United States Court of Appeals for the 9th Circuit overturned the United States Tax Court’s landmark Altera Corporation vs. Commissioner of Internal Revenue’s 2015 decision. The crux of the case centered around the requirement for cost-sharing agreements between controlled parties to include stock-based compensation. The case was heard by Chief
Transfer pricing was a hot topic in litigation this past year. Chevron settled a $340 million AUD tax dispute with Australian tax authorities, Amazon and Medtronic won their respective lawsuits against the IRS for millions in back taxes, and the EU targeted Ireland and Luxembourg for illegal state aid of large multinational companies attempting to
ktMINE’s Chief Operating Officer, John Wiora, was among the more than 40 Transfer Pricing leaders that shared their insights at the TP Minds West Coast Conference in San Francisco. Trending TP issues addressed at the conference included BEPS, digital economy taxation, managing risk, and the changing international landscape. Wiora led a breakfast discussion on the
As the OECD continues to evaluate and work on refining its transfer pricing guidelines regarding several BEPS initiatives, ktMINE CEO, David Jarczyk, and Director of Operations, John Wiora, explore the topic of ‘information asymmetry’. The article, “Challenging asymmetric data, leveraging public data”, concludes that by accessing publicly available global data, taxpayers and their consultants protect their analyses by
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.
The National Association for Business Economics (NABE) held its annual Transfer Pricing Symposium July 18-20 in Washington, D.C. ktMINE’s Brett Schoell, Market Lead of Transfer Pricing & BEPS, and Michael Taylor, Chief Technology Officer, attended the event, where ktMINE was a Gold sponsor. Following recent high profile transfer pricing court cases and updates to the
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.
On May 23, 2017 the Organisation for Economic Co-operation and Development (OECD) released the discussion draft BEPS Action 8 Implementation Guidance on Hard-to-Value Intangibles. The public was invited to comment on the draft “which provides guidance on the approach to pricing transfers of hard-to-value intangibles described in Chapter VI of the Transfer Pricing Guidelines.” President