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Transfer Pricing

Brazil Implementing OECD Transfer Pricing Reporting

14th March 2023

The long-awaited change from a proprietary Brazilian format transfer pricing report to an OECD format has been generally sought by companies for years.  Under the current draft legislation, which was announced December 29, 2022, the Brazilian Parliament has 120 days to transpose the draft into law.  The first hurdle is that Brazil has both a ...

Is it Time to Embrace Blockchain for Transfer Pricing?

07th March 2023

When you hear the term blockchain mentioned with respect to transfer pricing, it’s generally related to operational transfer pricing to ensure policies are in line. But if we think about what blockchain represents—a decentralized, immutable ledger—it opens up many other use cases for transfer pricing. One of the most powerful use cases I can think ...

The Center of Tax Policy

21th February 2023

For decades, both the Organization for Economic Cooperation and Development (OECD) and the United Nations (UN) have provided models for tax treaties between countries, and today, all existing tax treaties are based on the OECD model tax convention and/or the UN model. The essence of a tax treaty is to allocate taxing rights between countries ...

Do You Have to Perform Fresh Transfer Pricing Analyses Every Year? Here’s Why You Should.

14th February 2023

When speaking with customers, I regularly receive this question: Why should I redo my benchmarking search every three years? If nothing has changed, can’t I (or shouldn’t I) just keep refreshing the financial data of my comparables until something changes? It’s a fair question. After all, Chapter 5 of the OECD Guidelines (Paragraphs 5.37 and ...

Will Volatile Foreign Exchange Rates Impact Your Arm’s Length Range?

07th February 2023

Given the current volatile currency exchange rate landscape, and the approaching year-end for many, taxpayers should take the time to consider what implications it may have on transfer pricing. The first step is to review your intercompany agreements, and ensure they are aligned with how exchange rates are being handled operationally. In other words, do ...

Weathering Economic Uncertainty with Intercompany Financial Agreements

31th January 2023

Intercompany agreements (ICAs) have always been an important piece of transfer pricing compliance as they define the terms of intercompany transactions. However, in a volatile economic environment, when companies tend to inherit additional risk, these agreements become even more critical. “Intercompany agreements provide a reference to show what has happened in the external world and ...

The Problem with Pillar One

24th January 2023

OECD’s Two-Pillar solution appears to have more and more turning points as it is subject to global discussions on how the new tax rules should work to be efficient and fair. While some rules are gaining acceptance, others may become real deal-breakers. Many countries have had a hard time agreeing to Pillar One, which expands ...

Transfer Pricing and Inflation: Why Timing is Everything

19th January 2023

Global inflation can add a layer of complexity to your transfer pricing documentation, especially if you’re using transaction-based methods to conduct your analyses. When relying on the sales of product or services to third parties as your comparables via the comparable uncontrolled price (CUP) or comparable uncontrolled transaction (CUT), cost plus (CP), or resale minus ...

The Deceptive Cost-plus Method

17th January 2023

It was more than 10 years ago, when I listened to a European transfer pricing expert, at a prestigious transfer pricing conference, talk about how he applies a cost-plus method with a cost-plus markup of 5% on fully loaded costs. I found myself confused because once you look at fully loaded costs, it’s really the ...

Tax Resolutions for 2023

10th January 2023

A new year always begins with a few good resolutions. But we weren’t interested in the usual diet and exercise promises—we wanted to see how tax executives will be upping their games in 2023. So, we asked clients and a few of our own experts about their professional new year’s resolutions and here we’re listing ...