The Issue Behind 'Almost All' Transfer Pricing Cases: Ex Ante or Ex Post Basis

Skadden Podcast / GILTI Conscience: Casual Discussions on Transfer Pricing, Tax Treaties and Related Topics

Nathaniel Carden David Farhat Mithuna Sivaraman Stefane Victor Bram Isgur

In episode seven of "GILTI Conscience," hosts Nate Carden and David Farhat talk with Keystone Strategy's Bram Isgur about the issue underlying most major transfer pricing cases: whether to look forward to see what pricing should be for events that have not yet happened or to wait and look back at what has already occurred. As Bram acknowledges, there is no perfect solution: Transfer pricing theories are ex ante, transfer pricing audits are ex post, and OECD guidelines and U.S. transfer pricing rules are a mix of the two.

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