Articles in TP Hot Topics
Showing 14 articles in TP Hot Topics. Clear filter
Intercompany Services Transfer Pricing: How to Structure, Price, and Document Service Charges
A practical guide to transfer pricing for intercompany services: how to categorize services, select the right pricing method, establish arm's length charges, and avoid the most common compliance pitfalls.
Transfer Pricing and Customs: Coordination Under a Shifting Tariff Regime
Navigate the intersection of transfer pricing and customs valuation in the current US tariff environment, including the First Sale rule, year-end adjustments, and CBP-IRS coordination challenges.
Global Management Fee Charge-Outs: Pricing, Allocation, and Documentation
Practical guidance on structuring global management fee charge-outs: benefit tests, allocation keys, markup levels, and the documentation needed to defend intercompany service charges.
Transfer Pricing in Artificial Intelligence: A Sector Deep Dive
Explore the emerging transfer pricing issues in artificial intelligence: training data ownership, model IP location, GPU compute allocation, and how AI business models challenge traditional benchmarking.
IP Transfer and Exit Taxation: Transfer Pricing Considerations
The transfer pricing analysis of a cross-border restructuring: the before-and-after functional profile, testing the terms, and pricing the exit charge.
DEMPE in Practice: Aligning Intangible Returns with Functions, Risk, and Control
How intangible returns follow the entities that perform the DEMPE functions and control the risks, not the bare legal owner, and how to evidence where value sits.
The Profit Split Method Explained
What the profit split method is and the two forms it takes, the indicators that make it most appropriate, the profit to split, and the factors used to divide it.
Value Chain Analysis Explained
What a value chain analysis is, how it differs from a supply chain and a functional analysis, and how it tests whether profit aligns with where value is created.
Transfer Pricing in the International Tax Architecture
Understand where transfer pricing sits within the broader international tax system: its interaction with CFC regimes, GILTI/NCTI, BEAT, Pillar Two, withholding taxes, and treaty-based dispute resolution mechanisms such as MAP and APA.
Interest Rate Benchmarking for Intercompany Loans: CUP Approaches and Yield Construction
Pricing an intercompany loan with the CUP method: internal versus external comparables and constructing a yield from a risk-free base plus a credit spread.
Credit Rating for Intercompany Loans: Standalone Ratings, Implicit Support, and the Rating Build
Deriving a borrower's credit rating for an intercompany loan: standalone versus group rating, implicit support, and how notching sets the spread.
Debt Capacity and Borrower Analysis: How Much Debt Is Arm's Length?
The quantum question in a loan analysis: assessing a borrower's arm's length borrowing capacity, the metrics that bound it, and how excess debt is treated.
Pricing & Benchmarking Cash Pool Transactions
Setting arm's length deposit and borrowing rates in a cash pool, rating unrated participants, pricing cross-guarantees, and recharacterizing long-term balances.
Cash Pooling 101: Structures, the Pool Leader, and the Synergy Benefit
How groups centralize liquidity through cash pooling, the physical and notional structures, and how the cash pool leader is characterized and paid.