In light of the US Tax Court’s decision in Amazon v. Commissioner of Internal Revenue, many important predictions have been made about the impact this case will have on future transfer pricing litigation. However, it is important to look at the valuable lessons that should be learned by practitioners, corporations, attorneys, and tax authorities when documenting intercompany transactions, specifically intangibles. John Wiora, director of operations at ktMINE, investigates.
Unlock this content.
The content you are trying to view is exclusive to our subscribers.
The appointment of former Missouri representative Billy Long means Danny Werfel’s term will be cut short; in other news, former UK chancellor Philip Hammond has joined a tax consultancy’s board
PwC’s ability to ‘quarantine critical information’ should raise concerns for regulators worldwide, Deborah O’Neill said in her warning letter to the PCAOB
Problem solving skills are nothing more than a ‘nice to have’ for clients, according to new ITR+ research and conversations with six global in-house and advisory tax leaders
Despite China and India’s hesitation towards pillar two, there’s still enough movement in other countries for clients to start getting ready, James Badenach also tells ITR
The investigations dated back to 2015 and alleged that the companies received huge financial advantages from TP rulings; in other news, Australia is set to adopt a CbCR regime
Taxpayers would have to register controlled commodity transactions and declare information to the Brazilian tax authorities under the proposed regulations