The Growing Trend Of State Transfer Pricing Scrutiny

By Eric Tresh, Maria Todorova and Justin Brown (August 26, 2019, 3:01 PM EDT) -- The pricing of intercompany transactions is a significant issue for multistate and multinational corporations that, despite filing as part of a consolidated group for federal tax purposes, are nevertheless required to file separate-company tax reports in a number of states.[1] Currently, states around the country are examining corporate transfer pricing practices more frequently and with much greater scrutiny than ever before.

Over the last few years, states have used various approaches to challenge the validity and pricing of intercompany transactions. We have seen states rely on their statutes and regulations that either adopt Internal Revenue Code Section 482 or contain language...

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