Financier Worldwide Indepth Feature: Transfer Pricing 2023

Clark Armitage and Elizabeth Stevens offer insights in Indepth Feature: Transfer Pricing for the May 2023 issue of Financier Worldwide Magazine. To access the full roundtable article, please visit Financier Worldwide's website or click on the PDF in the Related Materials below.

Excerpt taken from the article.

Q: Could you outline some of the significant developments in the transfer pricing arena over the last 12 to 18 months? In what ways have these developments impacted how organizations go about implementing their tax planning strategies?

Armitage/Stevens: A key U.S. transfer pricing (TP) development is the publication of the 3M Tax Court decision. That decision, which was joined by the slimmest possible majority of Tax Court judges, found in favor of the Internal Revenue Service (IRS) in a Brazilian blocked income case. The court required the U.S. taxpayer to include in income arm's length royalties from its Brazilian subsidiary rather than the lower