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Legal Update

The Tax Act Changes the Game for Transfer Pricing

5 February 2018
Mayer Brown Legal Update
The “Tax Cuts and Jobs Act” (the “Tax Act”) fundamentally changes the US international tax system. Consequently, the Tax Act is a game changer for transfer pricing and international tax planning for both US- and foreign-parented multinational enterprises (“MNEs”). This Legal Update provides an overview of some of the provisions of the Tax Act most relevant to international structuring and transfer pricing-related decisions, as well as some general considerations and takeaways for both US- and foreign-parented MNEs regarding the Tax Act’s impact on common intercompany transactions and potential planning opportunities and pitfalls.


  • Jason M. Osborn
    T +1 202 263 3386
  • C. Cabell Chinnis
    T +1 650 331 2020
  • John T. Hildy
    T +1 312 701 7769
  • Brian W. Kittle
    T +1 212 506 2187
  • Thomas Kittle-Kamp
    T +1 312 701 7028
  • William G. McGarrity
    T +1 312 701 8928
  • Scott M. Stewart
    T +1 312 701 7821
  • Gary Wilcox
    T +1 202 263 3399
  • Lucas Giardelli
    T +1 212 506 2238
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