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.
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