Transfer Pricing and Valuation in Corporate Taxation: Federal Legislation vs. Administrative Practice


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Bloomberg Tax & Accounting Advisory Boards

She is well-versed in City of Detroit tax matters, as well as other Michigan cities. Prior to being named Executive Director in , Mr. Garriott was the Director of the Arizona Department of Revenue, a position which he held since He was also Deputy Director of the same organization from He has also served in private practice with a Phoenix law firm Lewis and Roca. Supreme Court and U. Tax Court Bars. Haas holds a J. Peterson Award for Economics. He teaches in the areas of state and local taxation, international taxation and federal income taxation.

He is co-author, with his late father and John Swain, of the leading treatise on state taxation, State Taxation vols. Thomson Reuters rev. He is also co-author with Arthur Cockfield et al. Supreme Court and by state courts throughout the nation. Supreme Court briefs in cases impacting state taxation of multistate commerce and led a tax policy initiative addressing taxation of Internet transactions. Houghton has represented clients on a multi-jurisdictional basis with respect to significant tax disputes; negotiated favorable settlements with state and local jurisdictions; developed and advocated state tax policy and legislative positions that benefited client interests; and collaborated with clients to design transactional and organizational structures that have optimized direct and indirect tax burdens.

Prior to this role, he was Executive Director of the Multistate Tax Commission, and served as commissioner of the Tennessee Department of Revenue ; president of both the Federation of Tax Administrators and the Southeast Association of Tax Administrators; chief financial officer for the Metropolitan Government of Nashville and Davidson County; and an Internal Revenue Service revenue officer. She has extensive experience in general commercial litigation and has handled a wide range of state and local tax controversies, litigating or resolving state tax disputes across the nation, in courts and in administrative tribunals in more than 40 states and localities.

She advises clients on matters arising in all of the states and localities, at all stages from the earliest responses to initial audit inquiries, dealing with audit disputes, filing administrative protests, and handling them from beginning to end. She is familiar with and has handled disputes in courts in nearly every state, dealing with discovery issues, witness preparation, depositions, pre-trial proceedings, trials, and appeals. She has experience in just about every area of state and local tax, including corporate income and franchise taxes, sales and use taxes, personal income tax, utility taxes, state unemployment taxes, and unclaimed property.

She also advises on the state and local tax ramifications of various business transactions, and on tactics for reducing state tax problems before they become large and expensive. Brian provides tax services to clients across the U. He is sought after by clients across the firm for his advanced knowledge in state and local taxes. Douglas L. Lindholm, Esq. COST, with a membership of nearly multistate corporations, is dedicated to preserving and promoting equitable and nondiscriminatory state taxation of multi-jurisdictional entities.

A Partner with Williams Mullen, Stephanie Lipinski Galland has extensive legal experience in state and local taxation with an emphasis on representation before state and local taxing authorities in income, franchise, sales, use and unclaimed property controversies. She has represented clients in developing, implementing and defending tax positions in state audits. Her experience in a Fortune company, as a tax partner in a national law firm and in the Virginia Department of Taxation provides her with valuable skills in all areas of taxation. She possesses broad experience in corporate governance, including interaction with operations and supply chain functions.

Clients of the firm primarily include multinational companies from the Global 1, corporate business community. Prior to founding LCG, Mr. From , Mr. An acknowledgement by his peers and NYU of his knowledge, experience and accomplishments in the field of multi-state taxation. Fred O. He has also written numerous articles on state taxation. Bryan Mayster serves as State and Local Tax Managing Director at PricewaterhouseCoopers where he has more than 27 years of experience consulting with clients.

His focus is on monitoring significant legislative, judicial and administrative state and local tax developments. Bryan assists clients so they are in a better position to monitor changes from an uncertain tax position perspective. Nachbar has served companies in a wide range of industries, including manufacturing, retailing, distribution, financial services, telecommunications, transportation and media.

Previously, Mr. Nagel was in private practice representing well known clients on tax and business matters, including multi-million dollar controversies. Nagel is an adjunct professor at the Georgetown University Law Center. Professor Richard D. Pomp is a summa cum laude graduate of the University of Michigan and a magna cum laude graduate of Harvard Law School. Professor Pomp has served as an expert witness in various courts throughout the country and as counsel and a litigation consultant to law firms, corporations, accounting firms, and state tax administrations.

He has participated in various capacities in U. Supreme Court litigation. Congress, the U. Smith received his B. He has been involved as counsel in well over a thousand controversies and disputes regarding countless tax issues before the administrative and judicial systems of numerous jurisdictions, and assisted in hundreds of transactions and planning situations providing strategic advice. He also serves on several advisory boards, including those for the Paul J. Sommer has written extensively in the area of state and local taxation. His articles have appeared in numerous publications.

Daniel L. He is a lecturer for various tax organizations and tax conferences. Stanley received a B. Philip M. She devotes her practice to state and local taxes on a nationwide basis for multistate and multinational corporations. Based in Washington, DC, Mr. He also leads its state and local transactions practice. Prior to moving to Washington, Mr.

He also served in various positions in New Jersey state government, including in the Office of the Governor. Jamie C. Yesnowitz has 15 years of broad-based SALT consulting experience at the national and practice office levels in large public accounting firms. He has extensive knowledge of state corporate income and sales tax legislation and policy; state tax conformity to federal tax provisions; and state corporate income tax apportionment rules. He has written numerous articles in national publications. Below is a list of our current board members.

For over 25 years, he has counseled North American and foreign-based multinationals and other institutions on their international and corporate tax concerns. Peter concentrates his practice in the taxation of corporate and international transactions. He advises public and closely held corporations and REITs in connection with their mergers and acquisitions, cross-border financings, restructurings, reorganizations, spinoffs and intercompany pricing.

Peter has advised entities in diverse fields, including real estate, infrastructure, finance, retail, manufacturing, mining, biotechnology, service software, transportation, telecommunications, beverages and pharmaceuticals. He has worked with institutional investors, private equity, hedge and venture capital funds, foreign governments, pension plans, Fortune 50 companies, investment banks, commodities and securities dealers, insurance companies, and others.

Manuel M. He is the author of several articles on tax law and a lecturer and panellist at national and international. She is a member of the International Bar Association and has been appointed as vice-chair of the Tax Committee for the period Guillermo O. He graduated LL. Adrian has advised on an extensive range of general income tax issues for Australian and international clients, with a special interest in tax issues in the energy and resources sectors and inbound and outbound investment.

Transfer pricing in the USA

His experience includes advising on taxation administration and compliance issues, comprehensive tax due diligence reviews and managing tax disputes. Adrian also has tax expertise in the automotive sector and infrastructure sector. He holds a bachelor of Economics and bachelor of Laws from the University of Sydney. Thierry Denayer is presently tax counsel at the Brussels office of Stibbe.

Thierry holds a law degree from the Katholieke Universiteit Leuven He practiced tax law in Belgium for 30 years at the Brussels office of Linklaters and since at Stibbe, specializing in national and international corporate tax. He was chairman of the Belgian branch of the International Fiscal Association from to Pascal Faes is a tax partner with Antaxius in Antwerp.

He received his J. He is a special consultant to Tax Management, Inc. Bloomberg Industry Group. Henrique concentrates his practice on international tax and transfer pricing. He is a member of the Brazilian Bar. Henrique received his LL. He has written numerous articles on international tax and transfer pricing.

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Henrique speaks English, Portuguese, and Spanish. Pedro received his LL. Pedro speaks Portuguese and English. Jay Niederhoffer is an international corporate tax partner of Deloitte, based in Toronto, Canada. Over the last 17 years he has advised numerous Canadian and foreign-based multinationals on mergers and acquisitions, international and domestic structuring, cross-border financing and domestic planning. Jay has spoken in Canada and abroad on cross-border tax issues including mobile workforce issues, technology transfers and financing transactions.

Rick Bennett has over 30 years of experience advising businesses and corporations on complex tax issues. He has served as lead tax counsel on several billion-dollar acquisitions and regularly advises clients in tax disputes with the Canada Revenue Agency. He focuses his practice on PRC tax and transfer pricing, mergers and acquisitions, foreign direct investment, and general corporate and commercial issues in China and cross-border transactions.

His main responsibilities were to draft and review tax and banking laws and regulations that were applicable nationwide. He represents U. He is an experienced tax litigator and has appeared before the Supreme Court more than 15 times since He is the author of several tax articles and publications. He was with Bech-Bruun from —, with Hannes Snellman from — and with Plesner from — Having practiced Danish law in London for a period of four years, he is now based in Copenhagen.

He specializes in international tax and transfer pricing. Thierry Pons is a partner with Cabinet Pons in Paris. He is an expert in French and international taxation. Thierry covers all tax issues mainly in the banking, finance and capital market industries, concerning both corporate and indirect taxes.

He has wide experience in advising corporate clients on international tax issues. He passed his two legal state examinations in and in Lower Saxony and took his L. Degree Harvard in and his Dr. He was an attorney in Stuttgart in and during he was with the Berlin tax administration. From until his retirement in he was on the staff of the Federal Academy of Finance, where he became vice-president in He has continued to lecture at the academy since his retirement. He was also a lecturer in tax law at the University of Giessen from to He maintains a small private practice as a legal counsel.

He has also advised several top technology companies on tax and structuring issues apart from publishing academic articles on taxation of digital economy. Mohan Parasan, Solicitor General of India between and , where he was involved in some landmark international taxation disputes in India.

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He has also been a regular speaker at conferences in India and abroad on issues relating to taxation of the digital economy, GAAR, MLI, artificial intelligence, cryptocurrencies and blockchain. Raghavan has a postgraduate degree in law and has also completed his management studies from Mumbai University. Prior to joining the firm, Mr. Raghavan is a frequent speaker on tax matters. He qualified as an Irish solicitor in and became a partner with the firm in He represents clients in every aspect of tax work, with particular emphasis on inbound investment, cross-border financings and structuring, capital market transactions and US multinational tax planning and business restructurings.

Louise Kelly is a corporate and international tax director with Deloitte in Dublin. She joined Deloitte in She is an honours graduate of University College Cork, where she obtained an accounting degree. Louise advises Irish and multinational companies over a wide variety of tax matters, with a particular focus on tax aligned structures for both inbound and outbound transactions. She has extensive experience on advising on tax efficient financing and intellectual property planning structures.

Louise is a regular author and speaker on international tax. Carlo Galli is a partner at Clifford Chance in Milan. He is a chartered accountant who has long focused exclusively on international and EU tax, corporate reorganisation and transfer pricing, and thus has significant experience in international tax planning, cross-border restructuring, and supply chain projects for both Italian and foreign multinationals. A regular contributor to Italian and foreign tax law journals, he is also a frequent lecturer in the field of international, comparative, and European Community tax law.

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His practice focuses on tax law matters, including transfer pricing, international reorganizations, anti-tax-haven CFC rules, withholding tax issues, and other international and corporate tax issues, and, with respect to such matters, he has acted as counsel in various tax disputes on behalf of major Japanese and foreign companies. He was admitted to the Japanese Bar in She transferred to Miami after working for three years in the New York office and five years in the Mexico City office of another Big Four professional services firm.

Since graduating magna cum laude from West Virginia University, she has more than 15 years of advisory services in financial and strategic acquisitions and dispositions, particularly in the Latin America markets. She is fluent in both English and Spanish. He graduated in tax law and notarial law at the University of Leiden and has a postgraduate degree in European tax law from the European Fiscal Studies Institute, Rotterdam.

He advises domestic businesses and multinationals on setting up and maintaining domestic structures and international inbound and outbound structures, mergers and acquisitions, group reorganisations and joint ventures. He also advises businesses in the structuring of international activities in the oil and gas industry. He is a contributing author to a Dutch weekly professional journal on topical tax matters and teaches tax law for the law firm school.

Maarten J. He graduated in civil law and tax law at the University of Leiden, and has a European tax law degree from the European Fiscal Studies Institute, Rotterdam. Maarten serves a wide range of clients, from family-owned enterprises to multinationals, on the tax aspects attached to their operational activities as well as matters such as mergers, acquisitions and restructurings, domestically as well as cross-border.

His clients are active in the consumer and industrial markets, travel leisure and tourism sector and the real estate sector. In and Maarten worked in Spain. He obtained a degree in law from Deusto University, Bilbao, Spain in His previous professional posts in Spain include inspector of finances at the Ministry of Finance, and executive adviser for International Tax Affairs to the Secretary of State.

A professor since at several public and private institutions, he has written numerous articles and addressed the subject of taxation at various seminars. He advises multinational, venture capital and private equity entities on their acquisitions, investments, divestitures or restructurings in Spain and abroad. He is a frequent speaker for the IBA and other international forums and conferences, and regularly writes articles in specialized law journals and in major Spanish newspapers.

He is also a member of the tax advisory committee of the American Chamber of Commerce in Spain. Walter H. A graduate of the University of Bern and New York University School of Law with a master of laws tax degree, he was admitted to the bar in Her practice area is tax law, mainly international taxation; inbound and outbound tax planning for multinationals, as well as for individuals; tax issues relating to reorganisations, mergers and acquisitions, financial structuring and the taxation of financial instruments.

She is fluent in German, English and French. Charles has wide experience of advising on a range of corporate and finance transactions. His clients range from multinational blue-chip institutions to private individuals. Transfer Pricing Forum features transfer pricing experts from more than 20 countries and provides unique, country-specific solutions to complex technical transfer pricing problems. He brings a comprehensive regulatory, commercial and advisory perspective to the fields of transfer pricing and business restructuring, with a focus on practical implementation.

Andrew spent eight years in industry as a global head of transfer pricing, and has led the transfer pricing practice in two FTSE FMCG multinationals. He has a strong focus on assisting growth companies with their global transfer pricing needs through the design of defensible and pragmatic solutions. Patrick has more than 11 years of transfer pricing experience and has worked across several industries, including automotive, chemical, consumer products, medical products, pharmaceutical, software, internet, and manufacturing.

She is responsible for chairing bilateral and multilateral transfer pricing events in non-OECD countries with her primary focus being the implementation of legislation in the transfer pricing area. In the past she has worked as a senior consultant for the transfer pricing group of a leading accounting firm and in the Taxation and Customs Union unit of the European Commission. He has been consistently rated as amongst the leading transfer pricing professionals in India. Rahul independently handles litigation for top companies at the Tax Tribunal and Authority for Advance Rulings, and has won several landmark rulings in the field of transfer pricing, creating precedents, both nationally and globally, in matters relating to Berry Ratio, Marketing Intangibles; Selection of Tested Party; Corporate Guarantee; Profit Split Method; Supply Chain nuances etc.

Prior to joining Dhruva, Rahul has been a tax partner in PwC and KPMG for almost two decades, including having served both organizations as their national transfer pricing leader. He joined KPMG in and has over 20 years of experience in advising multinational companies on corporate tax both domestic and international and transfer pricing issues. Dirk Van Stappen has also been appointed in and reappointed in as one of the 10 15 as from European business representatives of the EU Joint Transfer Pricing Forum of the European Commission.

Yves de Groote has an LL. HUB; he joined KPMG in and has over 10 years of experience in advising multinational organizations on transfer pricing issues. He has been involved in and conducted various tax planning and transfer pricing assignments, ranging from the preparation of European and global transfer pricing documentation including functional and economic analyses and comparables searches and domestic and international transfer pricing audit defense to the negotiation of uni-, bi-, and multilateral rulings and advance pricing arrangements APAs.

Cristian Rosso Alba has a well recognised experience in Tax Law, with particular emphasis in domestic and international tax planning, restructurings, reorganisations and international business transactions. Additionally, Mr. Rosso Alba has been a regular lecturer in the United States and speaker in domestic and international tax conferences and is the author of more than eighty articles appearing in specialised publications. Previously he was a director of an international transfer pricing firm, the transfer pricing leader for Asia at a global advisory firm, and a senior transfer pricing specialist for a Big Four firm in New Zealand, Canada, and Australia.

Douglas Fone has a long background in Big 4 firms, providing international tax and transfer pricing services since in London, Hong Kong, Singapore and Sydney. He has been devoted exclusively to Asia Pacific international tax and transfer pricing consultancy since Doug joined the global independent specialist firm Transfer Pricing Associates TPA in to lead the development of the business in the Asia Pacific region, and is now a partner of the global firm. TPA has grown to become the leading independent specialist transfer pricing firm in Asia, and has coverage in over 30 countries around the world.

She has over 22 years of experience and specializes in international taxation and transfer pricing. Her expertise includes the conceptual design of international tax structures and business models, defense in tax audits, litigation, and mutual agreement procedures, as well as the optimization of value chains from a transfer pricing point of view. Previously, she was Head of Corporate Taxes for Borealis AG, where she had overall responsibility for group corporate tax, including matters affecting tax risk management, transfer pricing, and international structures.

Alexandra received her education at the Vienna University of Economics and Business Administration, and she is also a member of the Austrian Chamber of Accountants. A specialist in tax law, Jerry has over 18 years of experience in tax consulting and administrative litigation. He counsels both domestic and foreign clients, with an emphasis on indirect taxes and taxation in the automotive, information technology, telecommunications, intellectual property, food, and cosmetics sectors. Prior to building his tax practice at TozziniFreire, Jerry worked as a tax manager in global audit and consulting companies.


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He frequently publishes articles on tax law in major national publications. Richard Garland is a partner in the Toronto office of Deloitte. He is a Chartered Professional Accountant and has over 25 years of accounting experience focused in the area of corporate international taxation. Richard has assisted clients in all aspects of international taxation, with particular emphasis on tax treaty issues, cross-border financing structures, and transfer pricing.

Chi has led many transfer pricing and tax efficient supply chain projects in Asia and Europe, involving advance pricing arrangement negotiations, cost contribution arrangements, Pan-Asia documentation, controversy resolution, global procurement structuring, and headquarters services recharges for clients in the industrial market including automobile, chemical, and machinery industries, as well as the consumer market, logistic, communication, electronics and financial services industries.

In addition to lecturing at many national and local training events organised by the Chinese tax authorities, Mr. Chi has provided technical advice on a number of recent transfer pricing legislative initiatives in China. International Tax Review. Chi has been recommended as a leading transfer pricing advisor in China by the Legal Media Group. He specialises in contentious tax including transfer pricing, tax litigation and business taxation advisory work.

Arne is the author of numerous Danish and international articles on tax and company law. He holds a Law degree, Aarhus University cand. He specializes in corporate and international tax matters. Casper is the author of numerous articles on international taxation. He holds a law degree from the University of Copenhagen cand. He assists French and foreign companies in their international investments, as well as in the course of their tax audits and litigations. He has extended the practice of transfer pricing and has intervened for French and non-French groups in setting up intra-group flows, IP companies, and business restructurings.

He is a member of the Paris Bar. He is an economist with 10 years of experience in transfer pricing, including in particular intangible valuation, business restructuring, transfer pricing policy design, and litigation. Guillaume has conducted a number of transfer pricing projects for multinationals in a wide range of industries, including high-tech, consumer goods, automotive, luxury goods, financial services, health care, real estate, media and entertainment, and energy. He is a regular contributor to the OECD and a frequent contributor to journals and trade publications.

During more than 25 years advising international corporations and leading law firms on transfer pricing issues, Alexander Voegele has specialised in the development of innovative economic structures for transfer pricing strategies and for the defense of major international transfer pricing cases. He has led hundreds of large transfer pricing projects and defense cases for a variety of clients in a range of industries.

He holds a doctorate in economics and a Master of tax and business administration from the University of Mannheim. He is a certified German auditor and tax adviser and is a French Commissaire aux Comptes. He has received numerous awards as a transfer pricing adviser and has frequently been ranked as a leading tax and transfer pricing professional.

Philip de Homont specializes in complicated transfer pricing audits and the valuation of intellectual property for international corporations and law firms. He has defended major transfer pricing cases throughout Europe and the Americas in a wide range of industries from consumer goods to financial services. Philip de Homont is the co-author of dozens of articles and two books on transfer pricing and intellectual property valuation. He has participated in various transfer pricing conferences. Irene Lee has practiced tax for 11 years, the last 7 specializing in transfer pricing matters involving the financial services sector.

She joined KPMG in Hong Kong in and advises banking, asset management, and insurance clients on transfer pricing policies, documentation, and risk management in the Asia region. She earned a Bachelor of Business Administration B. He is an experienced financial services transfer pricing advisor and works with clients from the banking, insurance, and asset management sectors. He also worked as a transfer pricing specialist in New York for over two years. Catherine has a particular interest in transfer pricing, competent authority matters, and business restructurings and also has extensive experience in structuring inward investment projects, mergers and acquisitions, and corporate reorganizations.

Catherine has published articles in leading tax journals. He is an expert in drafting and defending transfer pricing studies and intercompany agreements, with over 15 years of experience. Yariv counsels both multinational conglomerates and small start-ups on their transfer pricing matters, including multinationals which have no activity in Israel. Yariv has published articles on the subject of transfer pricing and has been asked to keynote as an expert in transfer pricing at several conventions in Israel, Europe, and the U.

Yariv provides counsel pro bono to the Israeli Navy Association. Yariv speaks Hebrew, English, French, and Italian and has often advised global clients in their local language. Aurelio Massimiano is a partner at Maisto e Associati, where he has practiced since , after having worked for the International Tax Office of the Italian Revenue Agency and, prior to that, for a Big 4 accounting firm. His areas of expertise are international taxation and transfer pricing.

Transfer Pricing and Valuation in Corporate Taxation

Marco Valdonio was admitted to the Association of Chartered Accountants in He joined Maisto e Associati in after working for another tax law firm. He headed the London office from to and has been a partner in the firm since He graduated cum laude in Economics from the University of Parma in His areas of expertise include corporate taxation and group taxation.

He has more than 14 years of transfer pricing experience, including 6 years at Deloitte Touche Tohmatsu both Tokyo and New York , and international banking experience prior to transfer pricing. He has worked extensively with transfer pricing issues worldwide and is especially experienced in Japan, U. He has also worked with a broad range of clients in manufacturing, financial services and telecommunications and has assisted many taxpayers in negotiations with the Japanese tax authorities on transfer pricing audit examinations.

Takuma has authored articles for professional journals including Bloomberg Industry Group Transfer Pricing Report and Monthly International Taxation of Japan, and is a frequent speaker on transfer pricing topics. He also led the Advance Pricing Agreements Program in Mexico, where he negotiated over unilateral agreements and 34 bilateral agreements.

His impressive track record also includes proposing amendments to legislation on various matters for Latin American countries, and representing Mexico before the OECD for the transfer pricing party WP6. He received a Business economics and tax law degree from Erasmus University in Rotterdam in and a Tax law degree from University of Cologne in He specializes in international taxation and transfer pricing, Gaspar advises on financial transactions e.

He has specialized in transfer pricing services since and has worked both in the Netherlands and the United States. He has worked with many multinational enterprises in the broader field of transfer pricing planning, including risk and controversy management. His experience covers a wide range of industries, including the chemicals, pharmaceutical, high-tech and technology, consumer products, media, and telecommunication sectors.

He has been involved in a significant number of advance pricing agreements, both on a unilateral and multilateral level and has been involved in many mutual agreement procedures with many different countries across the European, Asian, and American continents. He has also effectively used APAs and rollback mechanisms to resolve transfer pricing disputes. He works with many companies on transfer pricing risk management to assist in defining the overall transfer pricing policy, the corporate transfer pricing function, and associated processes for ensuring sustainable and manageable transfer pricing models.

Danny has also worked with many international companies on the transfer pricing aspects of acquisitions and divestures. Danny regularly speaks at forums and events about transfer pricing, business restructuring, and international developments in taxation, including BEPS and state aid. He holds a degree in tax law from the University of Tilburg. TPEQ provides transfer pricing services in Australia and New Zealand across an extensive range of industries, transactions, and engagements, including APAs; independent second opinions and expert advice; tax authority reviews, investigations, and audit defense; global, regional, and country-specific documentation.

Leslie has over 22 years of specialized transfer pricing experience based in the APac Region Sydney and Auckland and an additional 10 years of corporate taxation experience in Big Four accounting firm practices, specializing in mergers, acquisitions, bankruptcies, and reorganizations based in the United States New York City and Chicago.

She supervises projects on structuring, documenting, auditing and defending intercompany transactions for both local and international clients. In , she began working exclusively in transfer pricing. She advises clients in several aspects of transfer pricing, ranging from tax audits to comprehensive transfer pricing planning, structuring of intercompany transactions and defensive documentation. Her experience spans a wide range of industries including communications, technology, media, financial services, automotive, consumer goods, tourism and pharmaceuticals. Over more than 14 years, Dr.

Kim has represented multinational corporations in various industries in transfer pricing audit defense, advance pricing agreement negotiations, mutual agreement procedures, and planning and documentation studies. Prior to his previous position, Dr. Before specializing in transfer pricing, Dr. He holds a Ph. The group has over 40 specialists, including ex-KNTS officers and economists with global backgrounds.

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Evgenia joined the firm as a partner in March Before that she worked for more than 15 years with another Big Four company where she obtained extensive experience in providing advisory services to Russian and international companies on various areas of taxation and conducting business in Russia, structuring investments, and coordinating approaches to tax planning. Since Evgenia has been focusing on transfer pricing. Evgenia specialises on serving companies working in retail, consumer products and life science industries. He has advised multinationals across various industries throughout the planning, compliance, and audit cycle.

His practice is focused on transfer pricing controversy, intellectual property valuations, and business restructuring. He also consults with Singaporean academic institutions on transfer pricing and business restructuring matters. He is a member of the Chartered Institute of Taxation in the U.

Michael has substantial transfer pricing and tax advisory experience and has specialised in South African domestic and international corporate tax issues for over 20 years, advising many multinational corporations on a wide range of tax compliance, structuring and financing matters. Michael advises on a broad spectrum of transfer-pricing issues, from documentation and planning to dispute resolution, taking into account the unique circumstances of various African jurisdictions.

Michael is a visiting professor at the University of Johannesburg and is a regular speaker at professional conferences. He is also a co-author of the book International Tax: a South African Perspective now in its fourth edition , together with Professor Lynette Olivier of the University of Pretoria, which contains a chapter on transfer pricing.

Her work has spanned the financial, consumer products, energy and pharmaceutical sectors. Methods similar to the CUP method apply to:. The US regulations also authorise the use of the resale price method under Treasury Regulation Section 1. Methods similar to resale price and cost plus also apply to service transactions the gross services margin method under Treasury Regulation Section 1. The CPM is applied using publicly available data that can be readily accessed and relaxed standards of comparability.

Is there a hierarchy of preferred methods? Are there explicit limits or restrictions on certain methods? The regulations require consideration of the following criteria to determine the best transfer pricing method:. What rules, standards and best practices should be considered when undertaking a comparability analysis?

The US transfer pricing regulations contain a set of general rules for analysing comparability, as well as rules that are specific to certain kinds of transactions or transfer pricing methods. The general comparability criteria under Treasury Regulation Section 1. In general, a more relaxed set of comparability criteria applies to the use of the comparable profits method, which requires only the generalised comparability of functions, assets and risks Treasury Regulation Section 1.

More strict comparability criteria apply to the use of:. In addition, strict comparability criteria apply to using the profit split methods Treasury Regulation Section 1. It is good practice to consider whether the controlled transactions being analysed are routine in nature or have unusual characteristics. In general, routine distribution, manufacturing or service activities can be analysed using the CPM with a cursory functional and comparability analysis.

High-value transactions — especially licences of valuable intangible property or the provision of high-value added services or both — should be analysed with a rigorous functional analysis, taking into account all of the general comparability criteria set out above, and the specific comparability criteria required by the transfer pricing method chosen for the analysis. Are there any special considerations or issues specific to your jurisdiction that associated parties should bear in mind when selecting transfer pricing methods?

There are two classic types of transfer pricing case that require special considerations when selecting or applying transfer pricing methods in the United States. The first classic case is recurring losses or low profits incurred by a foreign-controlled US entity marketing and distributing products on behalf of a foreign-related party. The second classic case is where high profits are earned by a foreign affiliate of a US entity in a low-tax jurisdiction when the foreign affiliate is a licensee of intangible property licensed from the United States, including cases where the foreign affiliate participates in a cost-sharing arrangement with a US entity.

In the second type of classic transfer pricing case, IRS economists are generally reluctant to agree to use the CUT method as a basis for evaluating royalty rates.


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  • Instead, IRS economists typically apply the CPM to treat the foreign affiliate as a contract manufacturer or routine distributor, which has the effect of limiting any upside profit potential from the licence transaction. Accordingly, taxpayers using the CUT method must be prepared to discuss and justify why it, and not the CPM, is the best transfer pricing method. What rules and procedures govern the preparation and filing of transfer pricing documentation including submission deadlines or timeframes?

    In the United States, the preparation of transfer pricing documentation is not affirmatively required by law or regulation. The transfer pricing penalty provisions under Internal Revenue Code Sections e and h are triggered when taxpayers fail to reasonably comply with the documentation requirements. Transfer pricing penalties may be avoided if the following requirements under Treasury Regulation Section 1.

    What content requirements apply to transfer pricing documentation? A master file report is not specifically required. However, the 10 principal documents required for a US transfer pricing report will meet most requirements for a master file report. A country-by-country report that meets the Organisation for Economic Cooperation and Development base erosion and profit sharing standards is required for tax years beginning after June 30 Treasury Regulation Section 1.

    The report is filed with the US income tax return on Form and the schedules included with the form. What are the penalties for non-compliance with documentation and reporting requirements? This penalty applies:. The documentation must be made contemporaneously and must be completed and in existence when the company files the relevant federal income tax return.

    Transfer pricing documentation generally needs to be provided to the IRS within 30 days of a request being made.

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    What best practices should be considered when compiling and maintaining transfer pricing documentation eg, in terms of risk assessment and audits? There are two classic types of transfer pricing case that require special considerations when a taxpayer compiles transfer pricing documentation in the United States. The second classic case is one where high profits are earned by a foreign affiliate of a US entity in a low-tax jurisdiction when the foreign affiliate is a licensee of intangible property licensed from the United States, including cases where the foreign affiliate participates in a cost-sharing arrangement with the US entity.

    In many cases, IRS economists apply the CPM to treat the foreign affiliate as a contract manufacturer or routine distributor, which has the effect of limiting any upside profit potential from the licence transaction. Are advance pricing agreements with the tax authorities in your jurisdiction possible? If so, what form do they typically take eg, unilateral, bilateral or multilateral and what enterprises and transactions can they cover? Yes, advance pricing agreements APAs are available.

    APAs may be unilateral, bilateral or multilateral. APAs can cover any type of transaction that is subject to the US transfer pricing rules, as well as income allocations attributable to US permanent establishments. There is no limit on the types of entity that can apply for an APA. Section 3 of the Appendix to Revenue Procedure provides for two levels of fees for initial APA requests, depending on the combined gross income of the taxpayer and all commonly controlled foreign and US parties for their most recently completed month fiscal year.

    A taxpayer may file an unlimited number of initial APA requests within a single day period for a single fee, provided there are no more than two competent authorities. Transactions will qualify for this reduced fee if:. Are there any special considerations or issues specific to your jurisdiction that parties should bear in mind when seeking to conclude an advance pricing agreement including any particular advantages and disadvantages? At the heart of an APA is the agreement among the tax authorities to give effect to the approved transfer pricing method TPM. Less frequently, an APA will use one of the traditional transfer pricing methods recognised by most Organisation for Economic Cooperation and Development member countries — such as a comparable uncontrolled price, a resale price or cost-plus methods — or certain other methods eg, reasonable profit-split that have gained some acceptance as a fourth method.

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    Transfer Pricing and Valuation in Corporate Taxation: Federal Legislation vs. Administrative Practice Transfer Pricing and Valuation in Corporate Taxation: Federal Legislation vs. Administrative Practice
    Transfer Pricing and Valuation in Corporate Taxation: Federal Legislation vs. Administrative Practice Transfer Pricing and Valuation in Corporate Taxation: Federal Legislation vs. Administrative Practice
    Transfer Pricing and Valuation in Corporate Taxation: Federal Legislation vs. Administrative Practice Transfer Pricing and Valuation in Corporate Taxation: Federal Legislation vs. Administrative Practice
    Transfer Pricing and Valuation in Corporate Taxation: Federal Legislation vs. Administrative Practice Transfer Pricing and Valuation in Corporate Taxation: Federal Legislation vs. Administrative Practice
    Transfer Pricing and Valuation in Corporate Taxation: Federal Legislation vs. Administrative Practice Transfer Pricing and Valuation in Corporate Taxation: Federal Legislation vs. Administrative Practice

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