Articles in Transfer Pricing and Tax

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Transfer Pricing and Customs: Coordination Under a Shifting Tariff Regime
Transfer Pricing and Tax

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.

10 min Transfer Pricing in the International Tax Architecture
Transfer Pricing and Tax

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.

10 min