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.
Articles and Insights
Taxing the Digital Economy—As Simple as ‘A, B, C’?
8 Common Challenges To Trademark Royalty Deductions
CAP Updates Bring Transfer Pricing Issues to the Fore
The Alphabet Soup of Value—Making Sense of IRS’s New Transfer Pricing Model
FCD Model: A New Tool for APA Submissions
New Directive Formally Acknowledges Adoption of IRS Wide Position on Multiple RAB Shares in CSAs
The Problem With Prediction In Transfer Pricing
IRS Instructs Exam Teams to Hold Transfer Pricing Documentation to a Higher Standard
Outlook for U.S. Advance Pricing Agreements
International Compliance Assurance Programme—Oasis or Mirage?
BEAT Impact on Transfer Pricing Alternative Dispute Resolution
The IRS and the APA: Denial Is Not a Strategy
U.S. APA Program Changes Positively Impact U.S.-Japan APAs
Advance Pricing Arrangement Series
Advance Pricing Arrangement Series: Asia Pacific (May 5, 2020)
Advance Pricing Arrangement Series: Europe (September 3, 2019)
Advance Pricing Arrangement Series: Americas (June 24, 2019)
Advance Pricing Arrangement Series: China (June 10, 2019)
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
New Horizons for Dispute Resolution Under Pillar One's Amount A (February 2021)
A U.S. Perspective on Transfer Pricing and EU State Aid (October 2020)
The State of Country-by-Country Reporting (August 31, 2020)
A New Era for Secondary Transfer Pricing Adjustments? (August 24, 2020)
Tax Court to Decide on Foreign Taxpayer’s Right to Deductions in Adams Challenge (August 13, 2020)
COVID-19 and Dislocated Employees: DEMPE and Risk Control Considerations (June 2020)
Revisiting Transfer Prices and Intercompany Contracts in Light of COVID-19 (June 22, 2020)
Practical Implications of Denial of Review in 'Altera v. Commissioner' (June 20, 2020)
IRS issues APA statistics for 2019 (May 2020)
Advance Pricing Agreements and COVID-19 (May 25, 2020)
Advance Pricing Arrangement Series: Asia Pacific (May 5, 2020)
New Era of Risked-Based IRS Transfer Pricing Enforcement (March 30, 2020)
Transfer Pricing Implications of COVID-19 (April 2020)
EU Mandatory Disclosure Transfer Pricing Arrangements (March 2020)
