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Marc Levey

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On 18 December 2020, the OECD published Guidance on the transfer pricing implications of the COVID-19 pandemic (“OECD Guidance”) providing guidance to taxpayers when applying the arm’s length principle and applying the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2017 (“OECD TPG”) for periods impacted by the COVID-19 pandemic.

This guidance emphasizes the use of the existing OECD TPG and the arm’s length principle to tackle difficulties caused or aggravated by the COVID-19 pandemic. It focuses upon transfer pricing and operating transactions but notably does not deal with transfer pricing of financial transactions such as interest on intragroup debt, other important intracompany transactions, such as management fees, are also not dealt with in the OECD Guidance.

The OECD Guidance should not be viewed as an extension nor as a modification of the OECD TPG.

In brief The Tax Cuts and Jobs Act of 2017 (Public Law 115-97) (TCJA) made significant changes to Section 163(j) effective for tax years beginning after December 31, 2017. On December 28, 2018, Treasury and the Internal Revenue Service (IRS) published proposed regulations (“Proposed Regulations”) implementing the amendments to Section 163(j)…

Despite geopolitical shifts, uncertainty and various factors that seem to affect numerous sectors, the global luxury and fashion industry has tripled in the last 20 years to approximately $300 billion and continues to grow rapidly. But with that broadening and diversification comes a whole new set of business challenges to…