District of Columbia Confounds Opposition to its Transfer Pricing Strategy
Summary
The decision in that case invalidated Chainbridges transfer pricing method, with the ALJ determining the failure to separate Microsofts controlled transactions from uncontrolled transactions, as required by section 482 regulations, to the extent possible, resulted in the transfer pricing analysis being "arbitrary, capricious, and unreasonable," thereby invalidating the audit method.A status conference for these three related cases is scheduled for March 7, 2018, unless a settlement can be reached to avoid trial.Empowered by the dynamic myRyan work environment, which is widely recognized as the most innovative in the tax services industry, Ryans multi-disciplinary team of more than 2,100 professionals and associates serves over 14,000 clients in more than 45 countries, including many of the worlds most prominent Global 5000 companies.Related Links DALLAS, Feb. 12, 2018 /PRNewswire/ -- In a surprising decision, dissimilar to the previous ruling in Microsoft, 1 a District of Columbia Administrative Law Judge (ALJ) denied three motions for summary judgment in an order dated January 26, 2018, finding that the transfer pricing method developed by Chainbridge Software LLC ("Chainbridge") was not arbitrary, capricious, or unreasonable.The ALJs denial of the motions for summary decision concluded the Districts Office of Tax and Revenue (OTR) was justified in its implementation of this method.
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