Tuesday, November 4, 2014

At its NESTOA meeitng New Jersey tax officials proposed a transfer pricing services to be offered through the Multistate Tax Commission

At the suggestion of the New Jersey Division of Taxation during its NESTOA meeting revenue officials from the charter states designing a host of transfer pricing services to be offered through the Multistate Tax Commission will recommend that the project operate a six-month voluntary disclosure period for taxpayers to resolve related-party issues.

See Power Point at- http://www.state.nj.us/treasury/taxation/nestoa/pdf/NESTOATransferPricingDeck.pdf

Under the project design approach tentatively approved November 3 by the MTC's arm's-length adjustment service advisory group, the MTC would accept taxpayer applications to participate in a voluntary disclosure process from July 2016 through December 2016. The targeted date for transfer pricing voluntary disclosure agreements to be processed would be March 30, 2017.

The idea in part is for the MTC transfer pricing project to include activities that produce revenue early on, so that tax officials can justify continuation in the four-year charter period to budget staff in their states. Operating the program for its full four-year charter period would average about $2 million a year, or $200,000 per state if at least 10 states committed to participating in it.

Those figures include the costs of contracting with economic consulting firms for transfer pricing analyses and of hiring core MTC staff dedicated to the project

Also, it's possible that in the first quarter of 2015, the MTC will contract with one or more consulting firms to offer training to state revenue officials on how to identify transfer pricing audit issues and on how to secure the needed taxpayer documents.

Should the MTC Executive Committee agree in concept to the project, the advisory group expects to spend the early part of 2015 making final revisions to the design plan while members of the Executive Committee recruit states to participate.

The formal launch of the MTC transfer pricing program would occur in July 2015, followed closely by the issuance of a request for proposal bidding process for consulting firms to contract with the MTC. The plan is for the contract to be finalized in the fall of 2015, with the first round of transfer pricing study analyses solicited by the end of December 2015.