The following article is part of a series of case studies and articles which have been kindly contributed by Dr Harold McClure, a New-York based economist who has advised in the area of transfer pricing for many years. Action 13 of the Base Erosion and Profit Shifting project requires large multinationals to prepare a Master File along with Country-by-Country …

Apparently, the IRS believes that the quality of transfer pricing documentation may have declined. (See its FAQ guidance issued in April this year.) They believed it necessary to remind practitioners that TP documentation needs to be consistent with risk allocation in intercompany agreements. Isn’t that like having to remind a glazier that the glass …

Allotment (noun) a plot of land rented by an individual for growing vegetables or flowers. In my ignorance, I thought that allotments were something quintessentially British. But it turns out that it’s a phenomenon that exists all over the world. The one pictured above is in the village of Lindfield, West Sussex, where we live. I’m not an allotment …

The following article is part of a series of case studies and articles which have been kindly contributed by Dr Harold McClure, a New-York based economist who has advised in the area of transfer pricing for many years. In our previous discussion of customs valuations in China, we presented a hypothetical example to capture the two case studies noted …