Key takeaways
Host: Mark Nehoray, partner, Deloitte Tax LLP
Presenter: Kerwin Chung, Aydin Hayri, and Joe Tobin
The OECD’s December 2020 guidance on transfer pricing implications of COVID-19 encouraged tax authorities to give taxpayers the benefit of the doubt while also cautioning taxpayers against opportunism. What practical lessons have been learned since then? We’ll discuss:
- A brief update on economic and tax-technical aspects of the guidance
- How taxpayers have applied the guidance in their benchmarking, comparability adjustments, and data adjustments
- Challenges taxpayers have faced and how they have responded
- Recent issues with Competent Authorities and APAs
Meet the speaker
Mark Nehoray
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.
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