Clark Armitage Analyzes Transfer Pricing Disputes at TP Minds Americas


The workshop will use case studies to illustrate successful and failed APA strategies. We’ll identify which covered transactions are best suited for an APA, which TPMs are best received by APMA, and how to avoid procedural missteps. Participants will be invite to contribute their own stories for the group. The case studies will include:

  • A successful cost sharing buy-in under the new regulations
  • A failed APA that attempted to cover only post-intangible-migration transactions
  • A successful pharmaceutical development and marketing APA using capitalized costs as a proxy for value; and
  • A failed financial products APA that attempted to continue coverage in the face of materially changed facts


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