Amanda Worcester Martin

Amanda Worcester Martin is a partner within the Firm’s Global Tax Practice. She routinely advises companies on a variety of corporate and international tax matters, particularly in the areas of transfer pricing, tax controversy involving international tax issues, and corporate M&A matters. Amanda focuses her practice on the areas of corporate and international tax planning and tax dispute resolution, with an emphasis on transfer pricing. Amanda has worked on numerous Advance Pricing Agreements, competent authority negotiations, and transfer pricing documentation projects, and regularly helps US-based and foreign-owned multinational companies resolve corporate and international tax disputes, including through audit, IRS appeals and litigation. She advises clients on the development and analysis of intercompany pricing policies and has experience in preparing intercompany contracts. Amanda also has experience representing US-based companies with respect to tax aspects of corporate transactions, in particular mergers and acquisitions and joint ventures.

In brief On 22 November 2022, the Organization for Economic Co-operation and Development (OECD) released the Mutual Agreement Procedure (MAP) statistics for 2021 (“MAP Statistics”). The 2021 MAP Statistics were produced pursuant to Base Erosion and Profit Shifting (BEPS) Action 14, which seeks to improve the resolution of tax-related disputes between jurisdictions. In Depth The MAP Statistics cover 127 jurisdictions in 2021 (up from 118 jurisdictions in 2020) and nearly all MAP cases worldwide, and…