The IRS, OECD and taxing authorities from developed and developing countries have ramped up enforcement efforts with renewed focus on multinational enterprises' ("MNEs") transfer pricing policies.
The OECD implemented revised standards for transfer pricing documen-tation and a template for country-by-country reporting which is recommended to be adopted by MNEs with a revenue in excess of € 750 million and starting fiscal years beginning on or after January 1, 2016. The IRS released final regulations that align U.S. transfer pricing reporting requirements with those recommended by the OECD. Under the final regulations, the reporting requirements apply to fiscal years beginning on or after June 30th, 2016.
MNEs need to be prepared to document and defend the transfers of property, services and intangibles among affiliated entities in this changing regulatory environment, whether under existing regulatory requirements or the new OECD requirements.
- Implementation of Transfer Pricing Policies
- Preparation of IRS Required Transfer Pricing Documentation and Audit Defense
- Preparation of OECD and Other Foreign Transfer Pricing Documentation
When MNEs initiate global intercompany transactions, they need to establish pricing for those transactions.
The transfer pricing methodology that an MNE implements should reflect a reasonable return to the parties of the transactions based upon the functions performed, risks assumed and assets utilized. Marcum can assist by preparing benchmark reports that identify comparable transactions to support an arm's length pricing methodology. In addition, Marcum can advise on the implementation of intercompany agreements and other documen-tation to support the transfer pricing policies.
Transfer Pricing Brochure
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The Marcum 2016 Year-End Tax Guide continues our tradition of providing timely tax guidance for the upcoming year.
