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Tax & Business

Transfer Pricing

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Today's Transfer Pricing Environment

The IRS, OECD and taxing authorities from developed and developing countries have ramped up enforcement efforts with renewed focus on multinational enterprises' ("MNEs") transfer pricing policies.

The OECD implemented revised standards for transfer pricing documen-tation and a template for country-by-country reporting which is recommended to be adopted by MNEs with a revenue in excess of € 750 million and starting fiscal years beginning on or after January 1, 2016. The IRS released final regulations that align U.S. transfer pricing reporting requirements with those recommended by the OECD. Under the final regulations, the reporting requirements apply to fiscal years beginning on or after June 30th, 2016.

MNEs need to be prepared to document and defend the transfers of property, services and intangibles among affiliated entities in this changing regulatory environment, whether under existing regulatory requirements or the new OECD requirements.

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Related Services:      International Taxation   |   Transfer Pricing   |   International Individual Mobility Services   |   Certified Acceptance Agent
Marcum LLP's International Tax Services Group has expertise and technical knowledge to assist in transfer pricing support for clients. This includes:

When MNEs initiate global intercompany transactions, they need to establish pricing for those transactions.

The transfer pricing methodology that an MNE implements should reflect a reasonable return to the parties of the transactions based upon the functions performed, risks assumed and assets utilized. Marcum can assist by preparing benchmark reports that identify comparable transactions to support an arm's length pricing methodology. In addition, Marcum can advise on the implementation of intercompany agreements and other documen-tation to support the transfer pricing policies.

 

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Steven  Wintersteen

Partner
Tax & Business
Chicago, IL
 
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