New horizons for dispute resolution under pillar one’s Amount A Mark Martin and Thomas Bettge of KPMG in the US describe the Amount A tax certainty process in the recently released pillar one blueprint and explore how it might work... By Mark Martin & Thomas Bettge November 19 2020
US: Thinking through secondary transfer pricing adjustments Mark Martin and Thomas Bettge of KPMG in the US explore the nature and tax consequences of secondary adjustments arising from transfer pricing adjustments initiated by tax authorities or taxpayers. By Mark Martin & Thomas Bettge October 29 2020
Transfer pricing remains crucial as IRS CAP programme opens for 2021 Mark Martin and Thomas Bettge of KPMG in the US note the opening of applications for the IRS’ CAP programme’s 2021 year, and reflect on how the programme’s approach to... By Mark Martin & Thomas Bettge September 29 2020
A US perspective on transfer pricing and EU state aid Mark Martin and Thomas Bettge of KPMG in the US offer views on the role of the arm’s-length principle in EU state aid enforcement. By Mark Martin & Thomas Bettge August 31 2020
US: Tax Court to decide on foreign taxpayer’s right to deductions in Adams Challenge Mark Martin and Thomas Bettge of KPMG in the US report on the next steps in the Adams Challenge case following the tax court’s decision on the taxability of continental... By Mark Martin & Thomas Bettge August 10 2020
COVID-19 and dislocated employees: DEMPE and risk control considerations Mark Martin and Thomas Bettge of KPMG in the US address the transfer pricing implications of employees working outside their normal business jurisdictions during the COVID-19 pandemic. By Mark Martin & Thomas Bettge July 02 2020
IRS issues APA statistics for 2019 Mark Martin and Thomas Bettge of KPMG in the US discuss the most recent U.S. APA statistics in the context of broader trends. By Mark Martin & Thomas Bettge May 21 2020
EU mandatory disclosure impending for certain transfer pricing arrangements Mark Martin and Thomas Bettge of KPMG in the US explore the application of EU mandatory disclosure requirements to transfer pricing arrangements. By Mark Martin & Thomas Bettge April 27 2020
Transfer pricing implications of COVID-19: Revisiting pricing, contracts, and APAs Mark Martin and Thomas Bettge of KPMG in the US explore certain implications of the global COVID-19 pandemic for companies’ transfer pricing arrangements. By Mark Martin & Thomas Bettge April 15 2020
US outbound: US taxing jurisdiction over offshore decommissioning services upheld Mark Martin and Thomas Bettge of KPMG in the US take a closer look at the US Tax Court’s opinion in the Adams Challenge case and consider its implications for... By Mark Martin & Thomas Bettge February 24 2020
