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US Treasury economist states US preference on transfer pricing rules

20 September 2023

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Tax Alerts, Transfer Pricing, Transfer Pricing, BEPS 2.0

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United States

The US Treasury Department reiterated its preference for the adoption of “Alternative A” in the scoping rules for Amount B of Pillar One of the BEPS 2.0 project. The United States opposes new concepts in Amount B, as it believes that the primary goal of simplification cannot be achieved by incorporating new complexities. Bill Morgan, a financial economist at the US Treasury Department, told a panel at an International Fiscal Association’s international tax conference on September 12, 2023, that Treasury would prefer the adoption of Alternative A for the transfer pricing scoping criteria in Amount B.1“The whole idea here is...