While the current economic upheaval is unprecedented, good planning based on lessons learned from prior downturns can help. Principals Robin Hart and Anna Soubbotina from CRA’s US Transfer Pricing group discuss practical steps to take now, before year end, to avoid prolonged exposure to 2020 Transfer Pricing risks. The discussion covered what the pandemic means for intercompany contracts, benchmark results, year-end adjustments and financial statement impacts. Looking ahead to 2021, effective prioritization of corporate transfer pricing resources will be key. We explored ways to focus on areas of highest impact.
US Tax Court favors unspecified method to determine royalty rate
The first US transfer pricing court decision of 2022 was published on Thursday, August 18, 2022, specifically Medtronic, Inc. and Consolidated Subsidiaries v....