03 May 2022
Cross-Border Transactions and the New OECD Transfer Pricing Guidelines
The importance of the Organization for Economic Cooperation and Development (OECD) Transfer Pricing Guidelines to tax administrations of countries is that they will assist such tax administrations in developing rules that can prevent the artificial shifting of a multinational enterprise’s (MNE) profits outside of their countries and provide rules better ensuring that an MNE’s reported tax base reflects the MNE’s economic activity within that country.
Related Content
- Transfer Pricing Tax Fundamentals
Learn more about transfer pricing tax fundamentals. Topics include U.S. transfer pricing rules and regulations, transfer pricing methods, IRS penalties, documentation requirements, and advance pricing agreements.
- Transfer Pricing General Concepts Checklist
Use this checklist for key concepts to keep in mind when dealing with transfer pricing issues that can arise in transactions between commonly controlled companies or entities. You must determine pricing related to such transactions as if the parties were dealing with each other on an arms-length basis.
Practical Guidance Updates
Featuring the latest updates from your Practical Guidance account.
- Tax Key Legal Developments Tracker (Federal)
Stay informed on new developments:- Business Entities. IRS updates interest rates, yield curves, and segment rates for April 2022. I.S. Notice 2022-16; 2022-18 IRB 1.
- Business Entities. IRS announces applicable federal rates for May 2022. Rul. 2022-9, 2022-18 IRB 1.
- Excise Taxes and Credits. IRS provides relief from failure-to-deposit penalties imposed by R.C. Section 6656as those penalties relate to the excise taxes imposed on certain chemicals under I.R.C. Section 4661 and on certain imported substances under I.R.C. Section 4671. I.R.S. Notice 2022-15. 2022-18 IRB 1.
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- Check out the new Practical Guidance Author Center! Learn about the 1500+ leading attorney authors contributing to our 21 practice areas, and find out how you can Become a Practical Guidance Author.
- The Practical Guidance Journal Spring 2022 Edition features guidance for employers on COVID-19 vaccination, testing, and employee health data protection; climate change disclosure market trends; and updates related to the Secured Overnight Financing Rate (SOFR).
- New and Recently Updated Practical Guidance Content
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