Analysis

Tariffs Could Throw Advance Pricing Agreements Into Doubt

Law360 (November 16, 2018, 3:24 PM EST) -- Tariffs imposed on U.S. imports by the Trump administration beginning in 2018 are raising questions about the validity of transfer pricing agreements that predetermine the tax treatment of those materials and products for future years.

Whether the tariffs will necessitate renegotiation of advance pricing agreements, in which multinational companies and one or more governments settle on a method for allocating income among taxing jurisdictions, is not yet clear, tax experts said. What is clear is that the duties — such as the 25 percent imposed on steel — are having an effect that no one could predict, in some cases even...

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