The Division of Taxation of the State of New Jersey in the United States has announced a transfer pricing initiative that started last June 15 and will continue until March 2, 2023, aimed at companies that carry out intra-group transactions, which would be subject to transfer pricing adjustments.
Who can apply?
Taxpayers that carry out transactions with related companies may apply to this initiative, even if they are under audit or have a case pending before reaching the Appellate Division of said Division. However, it will not apply in a matter of litigation.
Implementation Date
Taxpayers must provide written confirmation of the initiative by September 15, 2022, and meet the deadlines established by the Division, including submitting all required transfer pricing information by October 31, 2022. As part of this agreement with the New Jersey Division of Taxation, the Division will agree to waive any applicable penalties or additional penalties, except for those adjustments related to federal rectifications.
Warnings
The Division cautions taxpayers who do not apply for this initiative that eventually, they may be assessed all applicable penalties, will not have any penalties waived, and will be audited under the Division’s regular audit trail.
Source: National Law Review 04/07/22
