FIN 48 interpretation spurs global review of TP positions
September 28, 2007
Sponsored Americas piece by Alan Granwell and Eric Ryan of DLA Piper US
For publicly-held US companies, the Financial Accounting Standards Board (FASB) has effectively prompted the largest review of transfer pricing issues in over a decade with the issuance of its Interpretation No 48, Accounting for Uncertainty in Income Taxes (FIN 48). These new rules, which are effective for accounting periods beginning on or after December 15 2006, provide a new accounting framework for analysing and recording all tax positions (such as tax deductions and allocations) on a company’s financial statements. FIN 48 requires a company to review its global tax exposures, not only for all affiliates, but also for all years open to adjustment by the relevant tax authorities.
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