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Transfer Pricing Documentation

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Not All Transfer Pricing CUPS Hold Water

11th October 2022

As I often tell clients, in the best of circumstances, transfer pricing comps are, at the very least, tricky. Anyone who has ever been through a painstaking benchmarking analysis knows that finding reliable comparables is a perpetual hunt for needles in haystacks. And let’s face it: Today’s aggressive tax environment–where transfer pricing methods are one ...

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The Clock is Ticking When Tax Authorities Request Your Local File

22th September 2022

Any important job can be a little stressful, but throw in a tight deadline and something as simple as brushing your teeth can become downright anxiety-provoking. No wonder the sound of ticking clocks and stopwatches are used to add layers of suspense in everything from horror movies to competitive cooking shows. Tax executives are no ...

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Today’s Challenges for Pillar One and Pillar Two

20th September 2022

By now you well know, Pillar One and Pillar Two are part of the OECD’s ongoing project of combatting tax evasion and shifting profits to low-tax jurisdictions. Pillar One (applicable for large multinationals) aims at allocating taxable income to countries based on revenue generated in countries. Pillar Two aims to ensure that income is taxed ...

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Master and Local Files Required in the UK: Are You Ready?

13th September 2022

A diverted profits tax. A diversion profits compliance facility. And yet no official master and local transfer pricing documentation requirements. It’s almost like HMRC wanted multinational companies to endure transfer pricing troubles. Of course, that’s about to change with the UK’s recent adoption of BEPS Action 13’s master and local file requirements, which take effect ...

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5 Key Factors to Get Your Benchmarking Analysis Right

06th September 2022

Global tax authorities in various jurisdictions might have different compliance requirements, which are important to understand and monitor. Regardless of the jurisdiction, the one thing in common is that the “benchmarking analysis” is the bedrock of transfer pricing compliance. Getting it right is one of the highest priorities for tax professionals when it comes to ...

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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 ...

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 ...