Mark Martin and Thomas Bettge of KPMG in the US explore the nature and tax consequences of secondary adjustments arising from transfer pricing adjustments initiated by tax authorities or taxpayers.
Mark Martin and Thomas Bettge of KPMG in the US note the opening of applications for the IRS’ CAP programme’s 2021 year, and reflect on how the programme’s approach to transfer pricing has shifted in recent years.
Mark Martin and Thomas Bettge of KPMG in the US report on the next steps in the Adams Challenge case following the tax court’s decision on the taxability of continental shelf charter income.
Mark Martin and Thomas Bettge of KPMG in the US address the transfer pricing implications of employees working outside their normal business jurisdictions during the COVID-19 pandemic.