Skip to main content

Transfer Pricing

The business team analyzes revenue charts and graphs with modern laptop computers Close up.Business analysis and strategic ideas.

Your Insensitive Chart of Accounts 

11th August 2022

For better or worse, the tax department does not own the chart of accounts (COA). And from a provision perspective, that’s a problem. Why? Allow me to climb up on my soapbox. Most companies do not maintain a COA that differentiates transactions in a manner that allows automation. For us tax people that makes it ...

night time scene of city

Vietnam’s Brilliant (?) Transfer Pricing Move

08th August 2022

Vietnam has implemented a very interesting interquartile range requirement for transfer pricing analyses prepared for Vietnam. In their regulations, the tested party must fall within the 35th to 75th percentiles of the arm’s length range, rather than the more traditional 25th to 75th. As Duke University professor Eddy Malesky points out in this podcast, “Audits ...

group of photographers taking photos

 Could Your Next Facebook Post Lead to a Transfer Pricing Adjustment?  

02th August 2022

Back in the 80s, an artist called Rockwell released the song, “Somebody’s Watching Me,” a popular record that at one point climbed all the way to number two on Billboard’s Top 100.  Fast-forward to 2022, and paranoia about being “watched” feels miscast in the social media age, where we are anxious to share everything, from ...

birds eye view of a city at night

It’s All About Control

28th July 2022

For a lot of people—certainly those from my generation—the word  “control”  brings back memories of Janet Jackson’s 1986 hit album, “Control.” Produced by the legendary Jimmy Jam and Terry Lewis, the album is about how Janet took control of her life and career.    “It is all about control and I’ve got lots of it…”  While ...

men sitting at table working

Why Gamble with TP Documentation When You Can Show Tax Authorities Your Best Hand?

26th July 2022

If you’ve ever played poker, then you must be familiar with the art of the bluff: You hold a beatable hand, but you act like you’re holding a royal flush. You project a daringly neutral face, and instead of contemplating all that you have to lose, you boldly raise, in hopes that your opponents will ...

Comps: Public or Private: That is the Question

19th July 2022

There are two schools of thought when it comes to comparables searches for transfer pricing analyses: Should you use publicly listed companies, which most likely means that the comparables will be regional in nature; or should you include privately held companies so that comparable searches are specific to the tested party’s jurisdiction? Tax authorities like ...

The One Predictable Aspect of Transfer Pricing: Change.

18th July 2022

Growing up, I thought I would be one of three things: a doctor, a lawyer, or a backup dancer for Janet Jackson. I never thought that I would end up in tax, let alone, a specialized niche of international tax like transfer pricing. But of course, I was also fascinated by technology—and that’s what led ...