US Tax Court holds UK treaty does not protect right to deductions Mark Martin and Thomas Bettge of KPMG in the US explore the conclusion to the Tax Court litigation in the Adams Challenge case, and note key takeaways for other companies. By Mark Martin & Thomas Bettge March 04 2021
OECD explores dispute resolution improvements Mark Martin and Thomas Bettge of KPMG in the US describe the OECD’s recent proposals for strengthening the Action 14 minimum standard, and explore how adopting these proposals could improve... By Mark Martin & Thomas Bettge January 28 2021
New IRS policy restricts telescoping for APA and competent authority resolutions Mark Martin and Thomas Bettge of KPMG in the US discuss the recent IRS announcement on telescoping for advance pricing agreement and competent authority cases, and explore what this means... By Mark Martin & Thomas Bettge January 26 2021
US: 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
