Barnes Dennig Transfer Pricing After Tax Reform and COVID-19 120920 - BD | Page 35
OTHER COVID / CARES ACT STRATEGIES
CARES ACT Opportunity ?
• Tax NOLs can be carried back five years - 21 % or 35 %(!)
• For multinationals , transfer prices drive where losses incurred
• Changes to transfer pricing may be warranted given COVID
• Numerous Foreign Tax Credit , FDII , GILTI , BEAT , 965 Repatriation complications – but could be significant cashflow