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Archive for Transfer Pricing Guidance

A New Paradigm: Global Transfer Pricing Management Organizes All Documentation And Master Files

Transfer Pricing Software - Trans-Portal

Companies need a “portal” that enables them to streamline their processes and organize their global transfer pricing documentation. Such a tool should make it easy for the MNE to facilitate worldwide collaboration among professionals within the company and among its advisors by incorporating project management tools, tracking capabilities and communication across the globe. We have introduced Trans-Portal, a comprehensive solution with features designed to:

  • Organize global transfer pricing documentation
  • Collect data, perform research and analyze transfer pricing risks
  • Update transfer pricing documentation (Master and Local files) efficiently
  • Collaborate with colleagues across the globe to coordinate joint efforts
  • Validate transfer pricing documentation by transfer pricing specialists

Trans-Portal’s purpose is to fulfill these fundamental needs. This intuitive, easy to use solution is designed to meet the market’s appetite for support to automate data collection; organize transfer pricing documentation such as the master file and local files, benchmarking studies and intercompany agreements; and manage transfer pricing risks. At the same time, Trans-Portal enables global teamwork both within the enterprise and with the company’s external service providers.

Tour Trans-Portal To Manage Transfer Pricing Documentation

 

Looming Transfer Pricing Exams & IRS Preparedness Measures (Part 3 of Series): “TPEP Execution Phase”

Doug Schwerdt

In this third article in our Looming Transfer Pricing Exams & IRS Preparedness Measures series, we highlight and summarize the essential aspects of the IRS’s Transfer Pricing Examination Process (TPEP) Execution Phase.

The Execution Phase immediately follows the opening conference and consists of continued risk assessment, fact finding, information gathering, and issue development. Stages of issue development include determining the facts, applying the law to those facts, and understanding the various tax implications of the issue. The issue team is advised to make every effort to resolve factual differences with the taxpayer.

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OECD Issues It’s Final Transfer Pricing Guidance On Financial Transactions

Robert Bachmann On Transfer Pricing Guidelines

On February 11, 2020, the OECD issued its final Transfer Pricing Guidance on Financial Transactions in a 46 page document which the OECD widely disseminated and which can be found on the OECD website. The report builds on the discussion contained in the non-consensus Discussion Draft on Financial Transactions published in July 2018 (“2018 Discussion Draft”). As the guidance is final, it will likely be heavily relied upon by many tax authorities when scrutinizing financial transactions.

The guidance contains five sections:
1. Interaction With Guidance In Section D.1 of Chapter 1
2. Treasury function
3. Financial Guarantees
4. Captive Insurance
5. Risk-Free And Risk-Adjusted Rates of Return
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