Tue, Feb 11, 2020

Duff & Phelps Featured in Bloomberg BNA Transfer Pricing Forum – 2019 Year in Review

Managing Director Susan Fickling-Munge, Directors Andrew Cousins, Stean Hainsworth, Ryan Lange and Elizabeth Patrun, and Vice President Sarah Stauner in Duff & Phelps' global Transfer Pricing practice, provide Australia, U.S. and UK perspectives in the December 2019 issue of Bloomberg BNA’s Transfer Pricing Forum.

Additionally, the firm’s Transfer Pricing Alliance partner, TP EQuilibrium AustralAsia, provide their insights from a New Zealand perspective.

In this issue, international transfer pricing practitioners identify key transfer pricing developments during 2019.

The topic on a year in review includes commentary on the following general areas:

  1. Legislation: new legislation or regulations that have impacted the transfer pricing landscape.
  2. Transfer Pricing Examinations/Audits: key features or developments in the transfer pricing examination/audit process. Responses consider the following questions:


    • With enhanced, post-BEPS transfer pricing documentation in several countries, have you encountered challenges in meeting the tax authorities’ expectations for adequate transfer pricing documentation and supporting data?
    • One of the goals of the BEPS project was increased transparency. To date, have you noticed an increase in the number or types of inquiries in response to an increase in data available to tax authorities (i.e., CbC report, rulings, etc.)?
    • What are the primary areas of focus by the tax authorities during transfer pricing examinations/audits?
  3. Mutual Agreement Procedures (MAP): key features or developments in the MAP process. Responses consider the following questions:


    • One of the commitments made by countries as part of the BEPS project was to resolve treaty disputes in a timely, effective and efficient manner. Have you noticed a change in the timeliness of a typical MAP case?
    • Many countries have enhanced their MAP procedures in response to the BEPS initiative. To date, have you noticed a change in the number of MAP cases initiated in your country or an increased willingness by taxpayers to consider MAP?
  4. Cases and Rulings: recent transfer pricing cases or rulings, including any changes in the volume or types of transfer pricing cases litigated or subject to rulings.
  5. What Can We Expect in 2020?: anticipated transfer pricing developments or issues that we should be aware of as we enter 2020.

Read the Bloomberg BNA Transfer Pricing Forum December 2019 issue here.

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