Transfer Pricing Times – Third Quarter 2020

In this edition of Transfer Pricing Times, we present insights on recent transfer pricing developments from around the globe.

In the “Effect of New Lease Accounting Standards on Intercompany Loan Benchmarking” article, we examine the ramifications of the new lease accounting standards for intercompany loan benchmarking in a transfer pricing context.

In the “Non-Resident Taxation of German Registered IP Rights” article, we discuss provisions in the German tax law that could allow for the imposition of withholding taxes on non-resident entities for transactions involving intellectual property registered in Germany.

In the “OECD's MAP Statistics – Overview and Discussion of Potential Strategies for MAP Applications” article, we provide a summary of the OECD’s recently published mutual agreement procedure statistics for 2018 and potential strategies to resolve double taxation that could arise from transfer pricing adjustments.

In “Asia's Response to the COVID-19 Impact – Transfer Pricing Documentation, Benchmarking and APAs”, we review the main aspects of the transfer pricing guidance in the COVID-19 era released by various Asian tax authorities.

In the “Bayer Canada Wins Judicial Review to Narrow an ‘Unreasonable’ Transfer Pricing Audit Query” article, we outline Bayer Inc.’s successful judicial review by Canada’s Federal Court and the implications of the Canada Revenue Agency issuing formal requirement notices during a transfer pricing audit.

Finally, in the “Increased Focus on Multi-State Transfer Pricing Demands Scrutiny of Domestic U.S. Transactions” article, we address how COVID-19 has renewed transfer pricing efforts by state tax authorities related to the pricing of domestic intercompany transactions.

We hope that you will find this and future issues of Duff & Phelps’ quarterly transfer pricing newsletter informative.