In this Tax Notes article, Robin Hart discusses how to reevaluate transfer prices based on market conditions caused by COVID-19 and mitigate complexities associated with year-end processes. Robin also examines how (re)structuring intercompany transactions with high upfront payments can be effective in deploying cash within a multinational group.
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One of the most common analyses in transfer pricing is on the cusp of being overhauled at a global level. This pending change has the potential to impact many...