Overview
Tax partners Steve Dixon and Amanda Pedvin Varma are Contributing Editors for the 2023 chapter on Transfer Pricing for Lexology's Getting the Deal Through. The chapter provides an overview of the U.S. rules; it covers pricing methods and documentation requirements and discusses crucial transfer-pricing know-how on topics like disputing IRS adjustments, pursuing treaty relief, and striking advance pricing agreements that involve the U.S. That chapter acts as a reference guide and is structured to facilitate cross-jurisdictional comparisons. In their Global Overview, Steve and Amanda discuss some thoughts on trying to achieve transfer-pricing certainty in the face of significant uncertainty in the broader international tax landscape (especially given ongoing OECD initiatives).
You can read the full chapter and Global Overview at Lexology.
