KPMG article: Worldwide trends in transfer pricing

Case studies address common transfer pricing issues in several representative jurisdictions

International disputes are constantly evolving, and some recent trends observed by transfer pricing professionals include:

Challenges based on the effect of government incentives
Heightened scrutiny of local documentation, including a focus on operating expense ratios
Required substantiation of development, enhancement, maintenance, protection, and exploitation (DEMPE) functions
A resurgence of the deductibility and cost allocation challenges that were common in the late 1990s and early 2000s
A focus on interest rate issues
Increased assertion of penalties

Read a September 2024 article* prepared by KPMG LLP that examines common transfer pricing issues that tax authorities across the globe are increasingly focusing on and includes case studies addressing common transfer pricing issues in several representative jurisdictions: Canada, Greece, South Korea, the Netherlands, Peru, and the United States.

^{* This article originally appeared in Tax Notes Federal (September 16, 2024) and is provided with permission.}

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KPMG article: Worldwide trends in transfer pricing

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