Barnes Dennig Transfer Pricing After Tax Reform and COVID-19 120920 - BD | Page 9
HOW ARE COMPANIES AFFECTED BY TP ?
• Every US company with international operations
• Every international company with US operations
• Goods , royalties , services , loans – all transfer pricing issues
• Some companies have US state tax issues
• “ Arm ’ s-Length Standard ”
• Principles similar globally ( OECD Guidelines )
• How can you “ prove ” transfer prices are correct ?
• What happens if a tax auditor disagrees ?