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.
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