Transfer Pricing Jobs in Massachusetts

We're tracking 4 live transfer pricing roles in Massachusetts.

About this market

Market context

Transfer Pricing in the Massachusetts context focuses on how related-party transactions impact the state's corporate excise tax, particularly concerning the proper allocation and apportionment of income for companies operating within a unitary business. It involves ensuring that intercompany charges and transactions between related entities reflect arm's-length principles to prevent improper shifting of income out of Massachusetts.

Massachusetts imposes a corporate excise tax that includes an income measure (8.0% on net income) and a non-income measure (ranging from $2.60 to $26.00 per $1,000 of tangible property or net worth) for most corporations. While Massachusetts does not have specific standalone transfer pricing regulations, the Department of Revenue (DOR) relies on its authority under G.L. c. 63, § 39A (for combined reporting) and federal Section 482 principles to adjust income that has been improperly shifted through related-party transactions, particularly in the context of unitary businesses or combined groups. This is crucial for multi-state and multinational corporations filing in Massachusetts to ensure proper apportionment of income to the state.

What's driving demand

  • Increased Multistate Operations
  • Complex Intercompany Structures
  • State DOR Scrutiny on Apportionment
  • Federal Transfer Pricing Audits

Regulatory timeline

  • OngoingMassachusetts Department of Revenue (DOR) Guidance on Combined Reporting PrinciplesOngoing
    source
  • 2023-11-20Massachusetts Technical Information Release (TIR) 23-10: Tax Provisions in 'An Act to Improve the Commonwealth's Competitiveness, Affordability, and Equity'Final
    source

Credentials that matter

  • CPA (Certified Public Accountant)essential
  • MST (Master of Science in Taxation)essential
  • JD/LL.M. (Taxation)essential

Skills & tools

Section 482 AnalysisIRC §39A (MA Apportionment)Economic AnalysisFinancial ModelingTax Research (federal and state)Audit DefenseIntercompany Agreement ReviewOneSource Transfer PricingBNA Tax Management Portfolios

Frequently asked

What is transfer pricing in Massachusetts?
Transfer Pricing in the Massachusetts context focuses on how related-party transactions impact the state's corporate excise tax, particularly concerning the proper allocation and apportionment of income for companies operating within a unitary business. It involves ensuring that intercompany charges and transactions between related entities reflect arm's-length principles to prevent improper shifting of income out of Massachusetts.
How does transfer pricing work in Massachusetts?
Massachusetts imposes a corporate excise tax that includes an income measure (8.0% on net income) and a non-income measure (ranging from $2.60 to $26.00 per $1,000 of tangible property or net worth) for most corporations. While Massachusetts does not have specific standalone transfer pricing regulations, the Department of Revenue (DOR) relies on its authority under G.L. c. 63, § 39A (for combined reporting) and federal Section 482 principles to adjust income that has been improperly shifted through related-party transactions, particularly in the context of unitary businesses or combined groups. This is crucial for multi-state and multinational corporations filing in Massachusetts to ensure proper apportionment of income to the state.
What credentials matter for Massachusetts Transfer Pricing Tax Professional roles?
Employers most often look for: CPA (Certified Public Accountant), JD/LL.M. (Taxation), MST (Master of Science in Taxation).
Which tools and systems appear in Massachusetts Transfer Pricing Tax Professional job specs?
Commonly cited: Section 482 Analysis, IRC §39A (MA Apportionment), Economic Analysis, Financial Modeling, Tax Research (federal and state), Audit Defense, Intercompany Agreement Review, OneSource Transfer Pricing.
How many Massachusetts Transfer Pricing Tax Professional roles are live right now?
4 live roles on taxjobs.ai.