Tag Archive: Transfer Pricing

Force Majeure: Examining the Post COVID-19 Intercompany Agreement Reality

As COVID-19 continues to shift everyday life and the global economy, accounting professionals are looking for information to help guide their clients through these trying times. These organizations will lean on their in-house experience and should pay close attention to the lessons learned during the 2008 market crisis. Force Majeure is a clause included within

How to Navigate BEPS

In light of the evolving Transfer Pricing landscape being caused by the BEPS project, there is uncertainty on how to validate your intercompany transactions structures. ktMINE offers a solution that makes structuring intercompany transactions easier. Imagine you need to structure an intercompany transaction between a US Based Insurance Company, called Insure Co USA, and their

ktMINE Comments on discussion draft on Actions 8, 9 and 10 : revisions to Chapter I of the Transfer Pricing Guidelines of the BEPS Action Plan

In its capacity as an intellectual property data company, and as a small business with significant interests in transfer pricing matters, ktMINE humbly submits the following comments related to the revised Discussion Draft. The Discussion Draft has a recurring theme, best communicated in the introduction as “rules to prevent BEPS by engaging in transactions which would not, or

Intangibles, Market Data and the OECD’s Action 8 Guidance

Authored by David R. Jarczyk, he challenges the perception that the Organization for Economic Cooperation and Development’s work on base erosion and profit shifting represents a move away from the arm’s-length standard and a surrender to the notion that insufficient market data exists for conducting comparability analyses. In fact, he says, the OECD’s latest draft on the transfer pricing of intangibles,

ktMINE OECD Compliance: Legal Ownership

Taxpayers and practitioners should determine legal ownership in order to inventory the intangibles under analysis, and to provide a starting point in determining economic ownership/benefit. Intellectual property, including patents, trademarks and license agreements, can be abundant for any single entity. Action 8 under BEPS plan of the Guidance on Transfer Pricing Aspects of Intangibles, acknowledges this

ktMINE OECD Compliance: CUPs

Taxpayers and practitioners should be looking for the existence of CUPs. The CUP or CUT method remains a preferred method for any transfer pricing analysis. However, the very existence and subsequent availability of comparable documents has been considered a myth. At ktMINE, we know this is far from the truth. The OECD acknowledges their existence