News & Analysis as of

Valuation Transfer Pricing

Update: Transfer Pricing and Customs Valuation Case Study Published on WCO Website

by DLA Piper on

On 29 April 2016 the World Customs Organization (WCO) published the full text of a case study where Customs takes into account a company's transfer pricing study based on the transactional net margin method (TNMM) in...more

"New Regulations Address Outbound Transfers and Transfer Pricing"

On September 14, 2015, the Internal Revenue Service (the IRS) and Treasury Department proposed new regulations addressing the tax treatment under Section 367 of the Internal Revenue Code (the Code) of certain transfers by...more

Global Tax News - July 2015

by DLA Piper on

EUROPEAN UNION RE-LAUNCHES FORMULARY APPORTIONMENT: KEY POINTS ABOUT THE CCCTB The European Commission has recently released a Communication to the EU Parliament calling for a re-launch of its proposal from 2011...more

Worthless Stock Deductions: Valuation, Transfer Pricing and Technical Considerations

by McDermott Will & Emery on

When a multinational enterprise (MNE) has affiliates that have become insolvent, the overall tax planning objective frequently is to secure a U.S. tax deduction (often ordinary) for worthless stock or debt. The essential...more

Supply Chain Efficiency: Valuation and Transfer Pricing Considerations

by McDermott Will & Emery on

Deriving maximum cost efficiency from the supply chain is a critical operational issue for multinational enterprises (MNEs) in certain regions. As taxation is typically one of a group’s largest costs, supply chain...more

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