Transfer Pricing Times - June 2019

Transfer Pricing Times – June 2019

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Executive Summary

In this edition of Transfer Pricing Times, we present the latest and most relevant transfer pricing issues and developments from around the globe.

In the “Dispute Between IRS and Medtronic Over IP Valuation Heading Back to Court” article, we discuss developments in the Medtronic transfer pricing case against the IRS involving large transfer pricing adjustments made by the IRS in association with intercompany intangible transactions. In association with an appeals ruling, the matter is being sent back to the U.S. tax court in April 2020 for additional development.

In the “Spanish Court Releases Ruling on Use of Multiple Year Data and Selection of a Point in the Arm’s Length Range” article, we review the Spanish Court of Appeal’s final ruling on transfer pricing adjustments arising from the Spanish tax authority’s audit of IKEA Distribution Services.

In the “OECD Releases Program for Reaching Consensus on Taxation of Digital Economy” article, we discuss the work plan released by the OECD outlining a process for establishing new global tax rules addressing the tax challenges associated with the rapidly expanding digital economy.

In the “TP Minds Holds Its First Canadian Transfer Pricing Conference” article, we discuss the inaugural TP Minds Canada conference, including presentations on transfer pricing dispute resolution and the shifting landscape of defining and valuing intangibles.

In the “Singapore Guidance on Commodity Marketing and Trading” article, we summarize the Inland Revenue Authority of Singapore’s transfer pricing guidelines which outline various factors that may affect the economic value attributed to such activities.

In the “LB&I Keeps Transfer Pricing Examination Process Current” article, we discuss the IRS’s continued review and update to the framework and guide for transfer pricing examinations, including their planning, execution and resolution.

Finally, in the “Mongolia Adopts OECD’s Three-tiered Transfer Pricing Documentation” article, we review the Mongolian Parliament’s revision to its transfer pricing regulations contained in General Taxation Law.

Note: Duff & Phelps’ transfer pricing practitioners have also provided a detailed discussion of the recently released opinion in the Altera transfer pricing case, including considerations for taxpayers, in “Ninth Circuit Appellate Court Overturns Tax Court in Altera Case”.

We hope that you will find this and future issues of Duff & Phelps’ monthly transfer pricing newsletter informative and reliable.


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