OECD Aligning Transfer Pricing In December of 2015, the US issued proposed regulations related to the implementation of OECD/G20 Base Erosion and Profit Shifting (BEPS) Project, Action 8-10 – Aligning Transfer Pricing Outcomes with Value Creation. (Have we lost you yet?) These proposed regulations would require US Multi-National Enterprises (MNEs) with annual revenues of $850…

CbC Not For Me? Think Again. OECD Aligning Transfer Pricing In December of 2015, the US issued proposed regulations related to the implementation of OECD/G20 Base Erosion and Profit Shifting (BEPS) Project, Action 8-10 – Aligning Transfer Pricing Outcomes with Value Creation. (Have we lost you yet?) These proposed regulations would require US Multi-National Enterprises…

US multi-nationals have long enjoyed the simplicity and tax certainty afforded by Cost Sharing Arrangements (CSA). In a CSA, participants share in the development of valuable intangibles in exchange for the right to exploit the resulting intangible. The cost of the development activity is allocated to the participants based on each participant’s expected benefit. (To…

Apple Eurozone Tax 348 million If there was any doubt regarding the changing international tax landscape, Apple became among the first of what is sure to be many multi-national enterprises to enter into a multi-million dollar tax settlement related to its European operations.  Italy’s La Republicca announced last week that Apple has agreed to pay…

Spotlight on Transfer Pricing The US Treasury Department (“Treasury”) and the Internal Revenue Service (“IRS”) released the much-anticipated US Country-by-Country (CbC) Reporting rules on December 21, 2015. These proposed rules, issued in the form of proposed regulation §1.6038-4, would require the ultimate US parent of a multi-national enterprise (MNE) group with annual revenues exceeding $850…

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