TEI Silicon Valley Chapter Program: Transfer Pricing: Controversy, Compliance, BEPS, & Planning

July 25, 2017

Rod Donnelly, Sanford Stark, and Bart Bassett spoke at TEI Silicon Valley on “Transfer Pricing: Controversy, Compliance, BEPS, & Planning” to an audience of 80 in-house tax professionals. They teamed with three PWC partners for the presentation.  

Topics included the following:

  • Final § 367 and Temporary § 482 regulations
  • BEPS Actions 8-10 vs. § 482
  • Documentation and compliance requirements
  • OECD attribution of profits to a PE
  • Treaty considerations (including Multilateral Instrument)
  • Recent audit experience
  • Litigated cases and consequences for taxpayers