Host: Mark Nehoray, partner, Deloitte Tax LLP
Presenters: Jamie Hawes, Kirsti Longley, and John Hughes, Director of IRS APMA program
According to OECD statistics, transfer pricing controversies increased more than 20 percent in 2019. How can Advance Pricing Agreements (APAs) and Mutual Agreement Procedures (MAPs) help multinationals mitigate transfer pricing risk? We’ll discuss:
- APMA Program updates, including the merger with the Treaty Assistance and Interpretation Team (TAIT)
- Impact of COVID-19 on APA analysis and negotiations
- Implementation of APA and MAP settlements, including restrictions on "telescoping"
- APMA approaches to multilateral APAs, including use of the Functional Cost Diagnostic workbook, and updates on the extent to which non-section 482 issues can be covered by APAs, including BEAT
Meet the host
Mark is a senior partner in the Los Angeles office of Deloitte Tax LLP. He is a founding member of Deloitte’s national transfer pricing practice in March 1990, as well as the founding member of its Los Angeles transfer pricing practice. Mark has more than 36 years of public accounting and private industry experience, primarily in the international tax and transfer pricing areas. He consults with multinational clients on transborder transactions, assists multinational companies with transfer pricing studies, and consults with clients on restructuring of foreign royalties and other foreign income streams. Mark led the team that successfully negotiated Mexico’s first-ever transfer pricing ruling.