Clark Armitage Addresses Transfer Pricing for Financial Transactions at NABE Transfer Pricing Symposium

This panel will discuss the current trends and developments around Transfer Pricing for Financial Transactions. Specifically, the panel will focus on the IRS approach to implicit support detailed in its memorandum AM 2023-008 and its implications and challenges for multinational companies. Additionally, the panel will provide an overview of the increased surge of audit activity and regulatory developments on this topic across the globe including a discussion on various relevant court cases.  The panel will conclude with a discussion around practical considerations and specific avenues open to companies to manage the risks of double taxation and uncertainty embedded in financial transactions.