Barnes Dennig Transfer Pricing After Tax Reform and COVID-19 120920 - BD | Page 27

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TRANSFER PRICING BEST PRACTICES

Review annual profit margins of each subsidiary

• Subsidiary losses / tax NOLs = Subsidiary tax risk

• Large profits in subsidiaries = Parent tax risk

• All open tax years

• Not the final answer , but a great starting point

• Utilizing tax NOLs can be a high return on investment

IRS success in Coke can be a template for other audits

• IRS more likely to raise transfer pricing as an issue