Mark Martin and Thomas Bettge of KPMG in the US discuss the recent OECD public consultation documents on tax certainty for Amount A of pillar one and related issues, and review key areas that remain undecided.
Mark Martin and Thomas Bettge of KPMG in the US discuss the Internal Revenue Service’s (IRS) advance pricing agreement (APA) statistics for 2021, and the state of the IRS APA programme.
Mark Martin and Thomas Bettge of KPMG in the US describe changes to section 174 of the US Internal Revenue Code and what this may mean for entities that provide contract research and development services to related parties.