Unbundling Your Way Out of BEAT — Can Cost Allocations Make a Difference?
Managing Director Michelle Johnson, Director Salim Vagh and Vice Presidents Midori Nakamura and Jesal Patel in Duff & Phelps’ Transfer Pricing practice provide insights in Bloomberg BNA’s Transfer Pricing Report.
As companies close their first tax year following the 2017 Tax Cuts and Jobs Act (TCJA), many multinational firms are planning around new provisions that will impact their intercompany transactions.
One area that is attracting significant attention is the new Base Erosion and Anti-Abuse Tax (BEAT) provision and how the identification and classification of intercompany expenses can minimize its potential effects.
This article summarizes the BEAT provision and discuss tax and transfer pricing considerations when determining the appropriate allocation of intercompany expenses.