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Inevitable Tax Risk from AI-Driven Audits

31 May 2023

The advent of AI and machine-learning tools is poised to revolutionize the way that tax authorities conduct audits and identify potential areas of noncompliance.  In fact, the $80 billion IRS budget includes the objective to deliver cutting-edge technology, data, and analytics.  Unfortunately, multinational enterprises (MNEs) that are not prepared for this future reality risk getting ...

Why Do I Need a Debt Capacity Analysis for My Loan?

24 May 2023

Recently, a number of countries have either indicated or adopted requirements that transfer pricing reports documenting loans include debt-capacity analyses as an integral part of proving those intercompany loans are arm’s-length arrangements. But what is a debt-capacity analysis and why is it important?  Believe it or not, you’re already familiar with a debt-capacity analysis. Think ...

The Value of Cost-Allocation Drivers

17 May 2023

As winter has turned to spring, I’m suffering from skiing withdrawal. While skiing in Vermont this winter, first time using a Mega Pass to multiple resorts, I couldn’t help but think about how the large multinational company that owns the various mountains—for the sake of anonymity, let’s call it Mega Mount Corp—handles its transfer pricing. ...

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Pillar One and Pillar Two: Where We Are Now

10 May 2023

It seems that the global tax initiatives are in full speed now as so many tax developments are in progress. Some of them were recently summarized during OECD tax talks held in February 2023.  The February OECD talks covered an update on the status of global tax initiatives like Pillar One and Pillar Two, G20 ...