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Unpacking Pillar One, Amount B from a Transfer Pricing Perspective

By Chad Martin and Ricardo Rosero, BaseFirma USA Background In late 2021, the OECD announced the preliminary design of its two-pillar approach to modernizing global taxation in the context of integrated, digitalized economies. Broadly speaking, Pillar One aimed to provide guidance on

Brazil’s Transfer Pricing Overhaul: A Narrowing Window for Action

Chad Martin, BaseFirma Denver Office Lead Introduction Despite the attention that has been directed to Provisional Measure No. 1152/22 (“the PM”) as it makes its way through Brazil’s legislative system toward becoming law (see BaseFirma’s original analysis of the PM here), it

Brazil Publishes Provisional Measure Adopting OECD Transfer Pricing Guidelines

Key Points in this Article Effective January 1, a “Provisional Measure” was published which significantly changes Brazil’s transfer pricing legislation by aligning it closely to the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (“the OECD Guidelines”).The Provisional Measure has

When the Price Isn’t Right

Transfer Pricing in the face of current macroeconomic conditions Chad Martin, Senior Manager/Office Lead, BaseFirma Denver Eduardo Emmerich, Senior Manager/Office Lead, BaseFirma Houston Overview In the last two years, multinational enterprises (“MNEs”) have faced a consistently turbulent and challenging macroeconomic environment at

Transfer Pricing for Start-Ups and International Expansions

Chad Martin, BaseFirma Denver Despite recent headwinds in global trade caused by supply chain bottlenecks and geopolitical conditions, multinational enterprises (MNEs) continue to grow in number, size, and economic importance. Companies in industries ranging from financial technology to biopharmaceuticals are seeking to

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