Financier Worldwide Roundtable: Transfer Pricing

Clark Armitage offers his insights in Roundtable: Transfer Pricing for the February 2023 issue of Financier Worldwide Magazine. To access the full roundtable article, please visit Financier Worldwide's website.

Excerpt taken from the article.

Q: Could you provide an overview of the main trends currently shaping the transfer pricing environment?

Armitage: The US global intangible low-taxed income (GILTI) rules changed the landscape of international taxation. Eventually, all countries likely will have some GILTI analogue, only stronger. Corporate income tax rates likely will increase because GILTI-like taxes raise the rate floor. In addition, developed countries face enormous debt burdens and likely will remain aggressive in transfer pricing (TP) enforcement. While a minimum tax can materially reduce the benefits of 'tax-haven' TP, higher corporate rates and aggressive enforcement increase the need for effective dispute resolution and the motivation for