transfer pricing

TEI Submits Comments to the Treasury and IRS regarding Proposed Regulations under Section 965

On October 9th, TEI submitted comments to the Treasury and IRS regarding proposed regulations promulgated under the transition tax imposed by section 965, as amended by the Tax Cuts & Jobs Act enacted in 2017.

TEI Submits Comments to the OECD regarding the Transfer Pricing aspects of Financial Transactions

On September 6th, TEI submitted comments to the OECD regarding its public discussion draft under BEPS Actions 8-10 on the transfer pricing aspects of financial transactions.

TEI Comments on Scope of Revisions to OECD Transfer Pricing Guidelines

On June 19, TEI submitted comments to the OECD regarding the scope of future revisions to Chapters IV and VII of the OECD’s transfer pricing guidelines. TEI’s comments focused on the practical aspects of any future guidance.

TEI Comments on OECD Discussion Draft Regarding Revised Profit Split Guidance

On September 8, TEI filed comments with the OECD regarding its public discussion draft on revised guidance on the use of profit splits.

TEI Comments On Singapore's Proposed Transfer Pricing Rules

On October 6, 2014,  TEI submitted comments to the Inland Revenue Authority of Singapore in response to an invitation for public comment on proposed rules governing transfer pricing documentation. Notable among its comments, TEI expressed concern that the proposed rules elevate Singapore’s transfer pricing documentation requirements to a higher level than those existing under the OECD transfer pricing guidelines ahead of final recommendations from the OECD’s base erosion and profit shifting (BEPS) project.

TEI Comments on OECD Transfer Pricing Documentation White Paper

On September 30, 2013, TEI submitted a letter to the OECD commenting on its White Paper on Transfer Pricing Documentation. TEI’s comments focused on the need to reduce the transfer pricing documentation and compliance burden on taxpayers by standardizing requests for such documentation across tax authorities.

The comments were prepared under the aegis of TEI’s European Direct Tax Committee, whose chair is Alexander Kölbl of General Dynamics. Benjamin R. Shreck, TEI Tax Counsel, coordinated the preparation of TEI’s letter.

TEI Comments on the Multistate Tax Commission's Section 482 Project

On March 4, 2013, TEI submitted a memorandum to the Multistate Tax Commission (MTC) urging it to abandon a proposed project aimed at creating model regulations governing the use of state statutory authority to adjust income and expenses between related parties (i.e., transfer pricing).