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Explore how data and technology are transforming transfer pricing. Watch this on-demand webinar to learn how modern tools enhance benchmarking, documentation, and audit readiness.| Exactera
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
Eaton’s Loss to IRS Sparks Concerns Over EU Privacy Compliance Aug. 22, 2025 Summary by Bloomberg AI A recent federal appeals court ruling allows the IRS to access data in a transfer pricing dispute, potentially putting multinational companies at odds with European Union privacy laws. The US Court of Appeals for the Sixth Circuit determined... The post Eaton’s Loss to IRS Sparks Concerns Over EU Privacy Compliance appeared first on Exactera.| 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
Exactera Tax Provision gives Hub Group the speed, accuracy, and usability they need, transforming a once tedious process into a streamlined and reliable workflow. Hub Group is a publicly traded, leading supply chain solutions provider headquartered in Oak Brook, Illinois, with offices throughout the United States. Our service offerings include a full range of freight... The post Case Study: How Hub Group Cut Tax Provision Time by 60 Percent appeared first on Exactera.| Exactera
As of January 13, 2025, state-level R&D tax credits are officially returning to Michigan. Under House Bills 4368 and 5099-5101, certain flow-through entities and entities subject to corporate income taxes can claim a credit on their IRC 41 qualified research expenditures (“QRE’s”) incurred in Michigan. This credit can be used to reduce the taxpayer’s liability,... The post Michigan R&D Tax Credits appeared first on Exactera.| Exactera
Watkins Completes the Tax Provision in Record Time and for a Fraction of the Cost with Exactera Tax Provision Based in Atlanta, Watkins Associated Industries is a private holding company with an extremely diverse portfolio that spans everything from seafood processing to insurance services to door and window manufacturing, and more. With hands in so... The post Case Study: Watkins Completes the Tax Provision in Record Time and for a Fraction of the Cost with Exactera Tax Provision appeared fi...| Exactera
The annual income tax provision may not be the flashiest part of corporate tax, but it is essential. For companies complying with ASC 740, accuracy is not optional. In our recent Tax Thursday session, Introduction to ASC 740 – Basic Theory & Fundamentals, we broke down provision rules, concepts, and common pitfalls so you can... The post ASC 740 Made Simple(ish): Your Guide to Tax Provision Basics 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
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
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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