Alston & Bird Tax Blog

OECD

How to Price in a Pandemic: New OECD Guidance on Transfer Pricing Challenges Caused by COVID-19

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Our International Tax Group examines how the Organisation for Economic Co-operation and Development’s new guidance reiterates the central role of the arm’s-length standard and provides guideposts for taxpayers and tax administrations as they analyze how the COVID-19 pandemic is affecting intercompany pricing. Comparability analysisLosses and the allocation of COVID-19 specific costsGovernment assistance programsAdvance pricing agreements Read the full advisory here. Alston & Bird has formed a multidisciplinary response and relief team to advise clients on the business and legal [...]Read more

Risky Business – Allocating Losses When Your Supply Chain Is Disrupted

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Should a subsidiary incur losses due to risks it assumed? Can a parent take on losses? Our International Tax Group investigates the nuances of regulations from U.S. and international agencies and offers actions multinational enterprises can take now to prepare for the tax implications of COVID-19-related disruptions.

Who bears and controls the risk?
Useful guidance from the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations
Actions to take now and in the future

Alston & Bird has formed a multidisciplinary task force to advise clients on the business [...]Read more

International Tax ADVISORY: Impact of the Multilateral Instrument of U.S. Taxpayers

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Nearly 70 countries have signed the OECD’s multilateral instrument – but the U.S. isn’t one of them. Our International Tax Group takes stock of how the MLI will prevent base erosion and profit shifting (BEPS) and what it all means for U.S. companies.

What is the multilateral instrument?
Why didn’t the U.S. sign it?
How will it impact U.S. multinationals?

Read the complete advisory here. [...]Read more

International Tax ADVISORY – IRS Issues Draft Form and Instructions for Country-by-Country Reports

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Ultimate parents of U.S. multinational enterprises now have instructions for Form 8975, the U.S. Country-by-Country Report. Our International Tax Group reviews what U.S. MNEs must do to comply with new U.S. filings requirements, as well as procedures for voluntary early filing intended to satisfy BEPS-related Organisation for Economic Co-operation and Development guidance in other jurisdictions.

Fixing the reporting mismatch
Revenue Procedure 2017-23
The form and instructions

Read the full International Tax Advisory here. [...]Read more