Law360 | Tax Pros Want Fast, Flexible OECD Transfer Pricing Guidelines

Our International Tax Group examines how the Organisation for Economic Co-operation and Development’s new guidance reiterates the central role of the arm’s-length standard and provides guideposts for taxpayers and tax administrations as they analyze how the COVID-19 pandemic is affecting intercompany pricing.

Alston & Bird has been shortlisted by International Tax Review (ITR) in three transfer pricing categories for the “Americas Tax Awards 2021.”

Alston & Bird has broadened its transfer pricing and international tax capabilities with the addition of counsel E. Miller Williams, Jr. in the firm’s Atlanta office. Joining from Ernst & Young, where he was a principal, Williams advises multinational companies on complex transfer pricing matters, with an emphasis on international transfer pricing controversy, audits, advance pricing agreements, competent authority, and intercompany planning and structuring.

COVID-19 has crippled economies throughout the world. One byproduct of this pandemic has been widespread supply chain disruptions across all industries. For the additional costs and losses caused by these disruptions, multinational enterprises, or MNEs, need to determine which entities in the supply chain should incur such costs and bear losses, in whole or in part. What steps should MNEs take now?

Can a parent take on losses? Or should the subsidiary incur losses due to risks it assumed? Our International Tax Group investigates the nuances of regulations from U.S. and international agencies and offers actions multinational enterprises can take now to prepare for the tax implications of COVID-19-related disruptions.