Expert commentary on comparable company studies, benchmarking methods, and regulatory compliance. Resources for in-house tax professionals and transfer pricing advisors.
ArticleUnderstand US §6662(e) and §6662(h) penalty thresholds, documentation defenses, and how to estimate transfer pricing penalty exposure for your multinational group.
ArticleA practical examination of transfer pricing for industrial manufacturing groups: manufacturer characterization (full-fledged, contract, toll), the aftermarket and service-parts business, engineering and NRE charge-outs, joint ventures and licensing, and the interaction with customs and Section 232 tariffs.
ArticleA practical examination of transfer pricing for consumer electronics groups: layered IP value chains, contract and toll manufacturing characterization, royalty pricing for semiconductor and brand IP, regional distribution structures, and the acute interaction with US tariffs and customs valuation.
ArticleA practical examination of transfer pricing for traditional asset managers: management and performance fee allocation, services-based versus profit-split approaches, sub-adviser fee splits, substance requirements, and benchmarking across asset class and strategy.
ArticleUnderstand 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.