Transfer Pricing

Top News

Aussie Tax Office Misses Transfer Pricing Review Goals

By Jack McLoone

In each of the past two years, the Australian Taxation Office came up short of its goal to review every use of transfer pricing for related party debt made by entities included in two major economic categories, a government audit revealed Wednesday.

3 Key Takeaways From The IRS' Latest Pricing Pact Snapshot

By Natalie Olivo

The IRS finalized a record number of advance pricing agreements in 2023, signaling the agency's increased effectiveness at completing accords at a time when its approach to transfer pricing litigation could fuel corporate taxpayers' urgency for seeking APAs. Here, Law360 breaks down three key takeaways from the agency’s latest APA report.

8th Circ. Urged To Revive IRS' Pricing For Medtronic

By Natalie Olivo

The U.S. government urged the Eighth Circuit on Monday to side with the IRS' method for pricing the intangible property that medical device maker Medtronic licensed to a Puerto Rican affiliate, arguing it's the only way to determine arm's-length royalty rates.

EU Parliament Wants Transfer Pricing Rules To Apply Sooner

By Natalie Olivo

The European Parliament voted Wednesday to adopt new transfer pricing rules that would take effect one year earlier than previously planned, sending the proposal to the European Union's council of member countries for consideration.

IRS' DOJ Referral Rules 'A Disaster,' Sen. Whitehouse Says

By Kevin Pinner

The IRS protocols for referring cases to the U.S. Department of Justice are "a disaster" for enforcing laws against bankers and other actors who help U.S. taxpayers evade taxes, Sen. Sheldon Whitehouse said Wednesday during a hearing on offshore tax evasion before the Senate Budget Committee.

Treasury Proposes Long-Awaited Stock Buyback Tax Rules

By Kat Lucero

The U.S. Treasury Department proposed a pair of long-awaited rules Tuesday that detail the calculation and reporting of a new excise tax assessed to publicly traded corporations that recently bought back their own shares of stock on the open market.


Expert Analysis

The Benefits Of Competent Authority In Int'l Tax Disputes

Multinational enterprises seeking relief from double taxation in a changing international tax landscape should consider utilizing the competent authority process, which provides both taxpayers and domestic tax regulators an efficient and effective means of dispute resolution, say David Farhat and Eman Cuyler at Skadden.

Taxpayer Considerations For La. Audit Program Participation

While the Louisiana Department of Revenue's recently announced transfer pricing managed audit program could resolve time-consuming, expensive audits for many taxpayers, companies nevertheless need to consider the attendant risks in participation, say Jaye Calhoun and William Kolarik at Kean Miller.

International Tax Reform's Implications For Transfer Pricing

As the Organization for Economic Cooperation and Development overhauls the global tax rules on base erosion and profit shifting, and the Biden administration rolls out new U.S. tax proposals, multinational enterprises need to prepare for the effects of these tax changes on their transfer pricing structures, say Mandy Li and Shuang Feng at MGO.

MORE COVERAGE

April 5, 2024 01:48 PM

Contrasts Emerge Between Taiwan Tax Bill, Regular Treaties

April 4, 2024 06:29 PM

IRS Penalties Proper In $11B Amgen Dispute, Tax Court Says

April 3, 2024 07:19 PM

IRS Says $28M In Fines Against Microsemi Adhered To Rules

April 3, 2024 05:57 PM

McDermott Adds Ex-Baker McKenzie Tax Pro In Chicago

April 1, 2024 06:37 PM

US Support For Pillar 1 Still In Question After House Inquiry

March 29, 2024 06:31 PM

APA Work Doubled In 2023, IRS Report Says

March 27, 2024 06:31 PM

Czech Transfer Pricing Audits Boost Tax Base By $248M

March 26, 2024 07:00 PM

Adjusting To Amount B's Rules May Bring Growing Pains

March 25, 2024 02:05 PM

EU Court Asked To Rule On VAT On Transfer Pricing Payment

March 22, 2024 06:50 PM

Stock Buyback Tax Regs Imminent, Treasury Official Says

March 21, 2024 06:27 PM

UN Could Enhance Global Tax Agenda Setting, Officials Say

March 21, 2024 04:28 PM

Wyden Probes Swiss Bank's Ties To Billionaire Under Scrutiny

March 19, 2024 06:55 PM

UN Experts Aim To Finalize Tool For Model Treaty Updates

March 19, 2024 04:39 PM

OECD Deputy Tax Director To Leave Post In June

March 18, 2024 05:43 PM

Gov'ts Widely Back Building Capacity Of Tax Authorities

March 15, 2024 01:46 PM

Direct Hit On Tax Regs Unlikely If Justices Ditch Chevron

March 15, 2024 01:35 PM

Colombia, Norway Aim To Harmonize UN And OECD Tax Work

March 14, 2024 05:59 PM

Economists Suggest UN Tackle CFC Rules, Other Tax Policies

March 14, 2024 02:12 PM

IRS' Signals On Economic Substance Doctrine Draw Scrutiny

March 13, 2024 08:23 PM

Siemens Asks Tax Court To Toss $1.2B IRS Bill