IRS Launches Compliance Campaign for Captive Services

US: The IRS has launched a compliance campaign to ensure US multinational companies are paying their captive service providers no more than arm's length prices. Source: IRS The section 482 regulations and the OECD Transfer Pricing Guidelines provide rules for determining arm’s length pricing for transactions between controlled entities, including transactions in which a foreign ... More

By |2019-04-24T07:18:39+00:00April 24th, 2019|Benchmarking, North America|0 Comments

US: What is the TCJA base erosion and anti-abuse tax (BEAT) and how does it work?

US: The BEAT, a new tax under the Tax Cuts and Jobs Act, limits the ability of multinational corporations to shift profits from the United States by making deductible payments to their affiliates in low-tax countries. Source: Tax Policy Center Over the past several decades, US multinational corporations have used a variety of techniques to ... More

By |2019-04-22T08:44:27+00:00April 18th, 2019|North America|0 Comments