In light of the US Tax Court’s decision in Amazon v. Commissioner of Internal Revenue, many important predictions have been made about the impact this case will have on future transfer pricing litigation. However, it is important to look at the valuable lessons that should be learned by practitioners, corporations, attorneys, and tax authorities when documenting intercompany transactions, specifically intangibles. John Wiora, director of operations at ktMINE, investigates.
Unlock this content.
The content you are trying to view is exclusive to our subscribers.
From pillar two and amount B to Apple’s headline EU Commission dispute, Martin Bonner and Yiwen Ping of Kreston Global argue that 2024’s key TP developments will inform 2025
Holland & Knight, Nelson Mullins and McCarter & English made the joint-most tax partner hires in the US last year, according to annual ITR Talent Tracker data
While the US’s dramatic exit from the OECD’s global tax deal naturally grabbed headlines, Trump’s premeditated move shouldn’t detract from pillar two’s lofty ambitions
Mid-market European private equity house Inflexion, which also backs law firm DWF, has agreed to acquire a minority stake in the Dutch tax advisory firm
In-house teams that want a balance of internal control and external expertise for pillar two should seriously consider co-sourcing models, Russell Gammon of Tax Systems argues