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US Inbound Corner
US Inbound Corner is a bulletin of the latest tax developments affecting businesses investing into the United States. Written by professionals of the Deloitte member firms, the newsletter provides invaluable insights on a broad range of topics affecting US inbound taxpayers.
- Managing transfer pricing risks with advance pricing agreements: Considerations for Japan-based multinational enterprises: Transfer pricing enforcement activities are expected to increase throughout the world as countries endeavor to handle the aftermath of the COVID-19 pandemic while continuing to adopt the Organisation for Economic Co-operation and Development’s base erosion and profit shifting final recommendations, and multinational enterprises (MNEs) revisit their existing structures and transfer pricing policies in light of the evolving tax climate. Many Japan-based MNEs have historically managed their transfer pricing in a proactive manner through advance pricing agreements (APA), where APAs often helped them resolve complex issues in a practical manner, giving tax transfer pricing certainty for multiple years at a time. There continues to be strong interest in APAs among Japan-based MNEs, including those that have not previously considered an APA as a component of their transfer pricing risk management strategy.
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