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North Carolina Announces Transfer Pricing Resolution Initiative for Corporate Taxpayers

Bloomberg Tax

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  • August 12, 2020

Kay Hobart wrote an article in Bloomberg Tax on the North Carolina Department of Revenue's new initiative to resolve complex disputes concerning corporations' North Carolina tax liability.

"According to the department, the purpose of the program is to 'fairly and consistently expedite the resolution' of transfer pricing issues and 'provide certainty and uniformity to taxpayers,'" Kay wrote. "The program also aims to 'reduce time in disputes.'"

"North Carolina is a 'separate entity' state, meaning corporations are not permitted to file consolidated or combined returns," she continued. "Instead, each corporate entity must file a return reporting its net income computed separately. As a result, North Carolina has had a long history with adjusting intercompany transactions among related companies. Historically, the Department of Revenue required 'forced combinations' to remedy perceived abuses of North Carolina’s tax system."

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