Transfer Pricing Dispute Resolution

Defending your transfer pricing policy

Thomas Herr

Thomas Herr

Principal, Tax - National Leader Transfer Pricing Services, KPMG LLP

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KPMG LLP’s (KPMG) Transfer Pricing Dispute Resolution (TPDR) Services team can help you resolve disputes and respond to challenges that come with transfer pricing controversy—domestically or globally.

Advance pricing agreements - The why and the how of here and now
Read about the historical and current motivation to pursue an APA and how to negotiate an APA

About Our Services

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Transfer Pricing Dispute Resolution - Overview

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Advance pricing agreements - The why and the how of here and now

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The Alphabet Soup of Value—Making Sense of IRS’s New Transfer Pricing Model

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FCD Model: A New Tool for APA Submissions

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New Directive Formally Acknowledges Adoption of IRS Wide Position on Multiple RAB Shares in CSAs

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The Problem With Prediction In Transfer Pricing

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IRS Instructs Exam Teams to Hold Transfer Pricing Documentation to a Higher Standard

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Outlook for U.S. Advance Pricing Agreements

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International Compliance Assurance Programme—Oasis or Mirage?

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BEAT Impact on Transfer Pricing Alternative Dispute Resolution

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U.S. APA Program Changes Positively Impact U.S.-Japan APAs

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Advance Pricing Arrangement Series

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Advance Pricing Arrangement Series: Asia Pacific (May 5, 2020)

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Advance Pricing Arrangement Series: Americas (June 24, 2019)

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Advance Pricing Arrangement Series: China (June 10, 2019)

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Post-BEPS Controversy Readiness

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Evolution and Future of the MAP

KPMG shares view on the mutual agreement procedure process and its future

KPMG shares view on the mutual agreement procedure process and its future

Latest insights

Latest insights

 

New Horizons for Dispute Resolution Under Pillar One's Amount A (February 2021)

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A U.S. Perspective on Transfer Pricing and EU State Aid (October 2020)

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The State of Country-by-Country Reporting (August 31, 2020)

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A New Era for Secondary Transfer Pricing Adjustments? (August 24, 2020)

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Tax Court to Decide on Foreign Taxpayer’s Right to Deductions in Adams Challenge (August 13, 2020)

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COVID-19 and Dislocated Employees: DEMPE and Risk Control Considerations (June 2020)

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Revisiting Transfer Prices and Intercompany Contracts in Light of COVID-19 (June 22, 2020)

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Practical Implications of Denial of Review in 'Altera v. Commissioner' (June 20, 2020)

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IRS issues APA statistics for 2019 (May 2020)

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Advance Pricing Agreements and COVID-19 (May 25, 2020)

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Advance Pricing Arrangement Series: Asia Pacific (May 5, 2020)

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New Era of Risked-Based IRS Transfer Pricing Enforcement (March 30, 2020)

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Transfer Pricing Implications of COVID-19 (April 2020)

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EU Mandatory Disclosure Transfer Pricing Arrangements (March 2020)

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