At the Multistate Tax Commission (MTC) Executive Committee Meeting in Spokane, Washington, the Arm’s-Length Adjustment Service (ALAS) Advisory Group provided an update on its transfer pricing effort. On May 7, 2015, the Executive Committee approved the Final Program Design for the transfer pricing program (the Program). After receiving approval from the MTC’s Executive Committee, ALAS
transfer pricing
Alas, the MTC Executive Committee Approves Its Transfer Pricing Program Design
After nearly a year of planning, the Multistate Tax Commission Executive Committee today approved the Arm’s-Length Adjustment Services Advisory Group Final Program Design. The following six states have agreed to participate in the Program: Alabama, Iowa, Kentucky, New Jersey, North Carolina and Pennsylvania.
View the full Legal Alert.
If They Build It, Will They Come? ALAS Advisory Group Prepares Final Program Design to Present to MTC Executive Committee Amidst Light Early Interest From States
The Multistate Tax Commission’s Arm’s-Length Adjustment Services Advisory Group met via teleconference to continue the design of a program to analyze intercompany transfer pricing. Since they last met on March 4, the Group sent invitations to 48 states to join the program. Of the responding 21 states, 4 states indicated an interest in joining the…
MTC Inches Closer to Developing Its Transfer Pricing Program
The Arm’s Length Adjustment Service Advisory Group of the Multistate Tax Commission continued its transfer pricing effort with a teleconference today to discuss its training and implementation program. This initiative has extended over a year, and the MTC is aiming for approval from the Executive Committee by May 2015. States…
Not in Our State: Indiana Rejects Federal Transfer Pricing Study to Justify Intercompany Pricing and Forced Combination
By Jonathan Maddison and Timothy Gustafson
The Indiana Department of Revenue determined that forced combination of an Indiana taxpayer, its wholly owned disregarded entity and its out-of-state parent company was appropriate where the disregarded entity generated 92% of the federal consolidated group’s sales but only 0.14% of the consolidated taxable income for the taxpayer. The…
Multistate Tax Commission Gauges State Interest in Funding Transfer Pricing Expertise and Expands Audit Program
At its Fall Meeting in Nashville, Tennessee on December 11-12, the MTC’s Executive Committee voted to formally contact states to solidify whether there is sufficient financial commitment to fund any potential MTC transfer pricing program. The MTC also formally announced that Iowa, Pennsylvania and Rhode Island will join the MTC audit program. Additionally, the MTC’s…
MTC Meets With Economic Firms to Continue Its Transfer Pricing Effort
The MTC continued its foray into transfer pricing. In a highly anticipated meeting, the MTC engaged with seven economics firms—all of which could potentially offer their services to the MTC—to determine how best to tackle state transfer pricing issues. With a target date of Summer 2015 for implementation of a robust transfer pricing audit program…
Multistate Tax Commission Targets Summer 2015 Implementation of Transfer Pricing Effort
On July 28, the Arm’s Length Adjustment Services Advisory Group (Group) of the Multistate Tax Commission (MTC) met for the third time at the MTC Annual Conference in Albuquerque, New Mexico. The Group began this effort on June 2 and met again on June 25 in furtherance of a Summer 2015 deadline to implement its…
MTC Speaks with Potential Transfer Pricing Vendors
On June 25, the Arm’s Length Adjustment Services Advisory Group (the Group) of the Multistate Tax Commission (MTC) met via teleconference to continue the process of developing a multistate arm’s length pricing adjustment service. States participating in the meeting included Alabama, Florida, Georgia, Iowa, Kentucky, North Carolina, Pennsylvania and the District of Columbia. The primary focus of the meeting was to follow up from the June 2 meeting in St. Louis.…
Continue Reading MTC Speaks with Potential Transfer Pricing Vendors
No “Best Method” in the Madness: Taxpayer’s Transfer Pricing Study Fails to Stop Forced Combination in Indiana
By Sahang-Hee Hahn and Timothy Gustafson
The Indiana Department of Revenue required an out-of-state clothing company and its subsidiary to file a combined Indiana corporate income tax return, determining that the taxpayer’s transfer pricing study was insufficient to establish that its intercompany transactions were conducted at arm’s length. The taxpayer was the parent of a…