Episode 52: TP implications of the Final and Proposed BEAT regulations

Overview

In this podcast episode, Paige Hill (PwC’s US Transfer Pricing Leader), Kartikeya Singh (a Transfer Pricing Partner for PwC’s national tax practice), and Lili Kazemi (Director, National Transfer Pricing Knowledge Management) discuss highlights of the Final and Proposed BEAT Regulations, including the impact of the BEAT regulations on transfer pricing, treatment of loss transactions, reversal of the position of the 2018 Proposed Regulations regarding Section 15 relief, what taxpayers should keep in mind with regard to the SCM exception, and what the regulations clarified (or did not clarify) on netting and cost sharing. The panelists also discuss key takeaways now that the regulations are in play, including how the final and proposed BEAT regulations have affected what companies see as short and long-term solutions.

For further information, please contact: Paige Hill, Kartikeya Singh and Lili Kazemi