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.
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....