The principle of “substance over form” is a key concept in international taxation and global transfer pricing. It states that the economic substance of a transaction—not merely its legal or contractual form—should dictate its tax treatment. In the context of transfer pricing, where related-party transactions must reflect the arm’s length principle, the concept of substance... The post Substance Over Form in Transfer Pricing: Aligning Transactions with Economic Reality appeared first...| Exactera
With the US’s October 15 transfer pricing deadline fast approaching, now is the time to decide how you will present intercompany transactions to the IRS. While the Large Business and International Division has lost 20% of its workforce, that’s no excuse for taking shortcuts on compliance. In fact, we’d argue that 2025 is the time... The post The US Transfer Pricing Deadline is Looming. Here’s What to Do. appeared first on Exactera.| Exactera
On December 29th, 2023, the Office of Chief Counsel of the Internal Revenue Service (“IRS”) issued Memorandum AM 2023-008 that provides guidance on the impact of Implicit support or the effect of group membership on intercompany loans and related areas, including passive association. The IRS has clarified that it is their position that it may... The post How Implicit Support Can Impact Intercompany Financing Arrangements: An IRS Transfer Pricing Perspective appeared first on Exactera.| Exactera
Stay ahead in transfer pricing by prioritizing consistency, automation, and robust documentation. Learn how structured data, scalable systems, and AI-driven tools help tax professionals reduce risk, ensure compliance, and prepare for future audits.| Exactera
As global business structures become increasingly complex, tax authorities are... Read more| InCorp Indonesia
Insurance Tools Eyed to Handle Rising Transfer Pricing Risks of 2025 August 1, 2025 Tariffs, IRS wins add to uncertainty in intercompany deals Insurers growing more comfortable, one executive says President Trump’s new tariffs and an increasingly aggressive IRS with some big court wins under its belt are prompting more companies to explore transfer pricing... The post COO Mimi Song Appears in Bloomberg Tax: Insurance Tools Eyed to Handle Rising Transfer Pricing Risks of 2025 appeared first ...| Exactera
Transfer Pricing Enforcement Hampered by IRS Cuts July 30, 2025 The IRS’ targeted enforcement campaign gained traction until the agency’s workforce and spending pools began to shrink this year, but a transfer pricing specialist urged taxpayers towards voluntary compliance and proactive recordkeeping. Villainization of Transfer Pricing Mimi Song, chief operating officer of tax services...| Exactera
Every country makes it own rules regarding the transfer pricing local file. What does that mean for taxpayers? Find out.| Exactera
Exactera’s Mili Diaz Colodrero explains how multinationals can build financial transaction frameworks that comply with increasingly strict transfer pricing requirements. The details of related-party loans, guarantees, and cash pools used to be rarely scrutinized. Intra-group financing attracted limited attention from tax authorities, with few exceptions, and was handled mostly through spreadsheets and basic assumptions. That...| Exactera
With the implementation of Law 14,596/2023 and Normative Instruction RFB 2,161/2023, Brazil has officially stepped into the OECD-aligned world of transfer pricing. While the shift brings several changes, one particularly practical development is the explicit recognition of country risk adjustments when using foreign comparables.| Exactera