Mark Martin and Thomas Bettge of KPMG in the US discuss the first published statistics on the International Compliance Assurance Programme and their implications for businesses looking to obtain tax certainty
Mark Martin and Thomas Bettge of KPMG in the US discuss the issue of implicit support and a recent IRS advice memorandum addressing transfer pricing for intercompany debt
Multinational companies face numerous year-end tasks but should not forget to file the treaty notifications that are required in certain US tax treaties, say senior tax practitioners from KPMG in the US
Mark Martin and Thomas Bettge of KPMG in the US analyse the 2022 mutual agreement procedure statistics for the US and discuss their significance for businesses
Mark Martin and Thomas Bettge of KPMG in the US discuss the tax certainty provisions of the Multilateral Convention for amount A and evaluate their utility for businesses
Mark Martin and Thomas Bettge of KPMG in the US discuss the US TP penalty regime and a recent shift towards more aggressive penalty enforcement by the IRS.
Mark Martin and Thomas Bettge of KPMG in the US discuss the latest consultation document on Amount B, which aims to simplify transfer pricing for baseline distribution activities and reduce disputes.
Mark Martin and Thomas Bettge of KPMG in the US discuss IRS alternative dispute resolution (ADR) and prevention programmes and how their underutilisation impedes effective tax administration.
Mark Martin and Thomas Bettge of KPMG in the US discuss the recently announced IRS procedures for reviewing advance pricing agreement (APA) requests and what these procedures mean for taxpayers.