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
We dive into our two favorite takeaways from this year’s Organisation for Economic Development and Cooperation (OECD) International Tax Conference were: 1) Choose the appropriate benchmarking method, and 2) analyze data beyond standard licensing agreements.
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.
In a landmark decision, Amazon won its battle with the IRS last week. Experts on both sides cited ktMINE as the source of information for their CUP/CUT analyses, with the tax court ultimately agreeing with Amazon’s position. Read more about the case on CNBC and take a look at the full ruling below. Keep an eye