Transfer Pricing

Top News

More Geographic Adjustments 'On The Table' For Amount B

By Molly Moses

Countries' ability to make further adjustments for geographic differences in the streamlined transfer pricing approach known as Amount B — part of the OECD's plan for reallocating taxing rights among jurisdictions — is "still on the table," an official from the organization said Tuesday.

Intracompany Prices Should Reflect Acquired IP, Panelists Say

By Molly Moses

When one company buys another for its intellectual property, the subsequent pricing of that asset between the now-related entities should reflect the value of what was acquired, transfer pricing specialists said Tuesday at a conference in Washington, D.C.

EU Opposed Fast-Tracking Reforms Under UN Tax Convention

By Kevin Pinner

The European Union is concerned that a majority of countries want to create early protocols simultaneously with a United Nations framework convention on international tax cooperation, according to a statement endorsed Tuesday by the bloc's finance ministers.

Chevron's End Doesn't Bear On 3M's Case, IRS Tells 8th Circ.

By David Hansen

The U.S. Supreme Court's recent overturning of Chevron deference doesn't warrant a reversal of a U.S. Tax Court ruling in 3M Co.'s transfer pricing case, the Internal Revenue Service told the Eighth Circuit on Friday.

Tax Haven Biz Revenues Per Worker Still Far Outpace Norm

By Kevin Pinner

Companies recorded median revenues per employee of $1.6 million in low-tax jurisdictions like Ireland, the Cayman Islands and Hong Kong and around $300,000 in all other jurisdictions in 2021, a difference that has narrowed since 2017, the OECD said Thursday.

Tractor Supply Incorrectly Shifted Income, SC Tells Court

By Sanjay Talwani

Transactions between Tractor Supply Co. and two of its affiliates inappropriately shifted income and improperly reduced the company's South Carolina corporate income tax burden, the state told an appeals court, urging it to affirm a ruling by an administrative judge.


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

July 5, 2024 11:08 AM

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Eaton Needs To Cough Up Docs In IRS Probe, US Says

July 1, 2024 02:19 PM

OECD Tax Chief Affirms Pillar 1 Progress As Deadline Passes

June 28, 2024 01:21 PM

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June 27, 2024 06:23 PM

Aussie Betting Site Can't Duck Taxes Tied To News Corp. Sale

June 27, 2024 06:21 PM

High Response To IRS Transfer Pricing Letters, Official Says

June 25, 2024 11:57 AM

New EU Chair Hungary Eyes Talks On Corp. Tax, But No Deals

June 24, 2024 12:07 PM

EU States Turn Down Transfer Pricing Proposal, Report Says

June 24, 2024 05:39 PM

Loss Guidance Will Cover Pillar 2, IRS Official Says

June 17, 2024 06:05 PM

OECD Tax Plan Is Developing Nations' Best Choice, Prof Says

June 14, 2024 06:54 PM

Eaton Says Court Improperly Required Int'l Employee Evals

June 14, 2024 06:44 PM

Mining Co. Entity Can't Deduct Loan Interest, UK Court Says

June 12, 2024 05:41 PM

Groups Push Back On Stock Buyback Tax Test's Scope

June 11, 2024 05:41 PM

Compliance Costs Outweigh Min. Tax Gains, Biz Reps Say

June 6, 2024 01:50 PM

EU Must Improve Country-By-Country Reporting, Group Says

June 6, 2024 08:22 PM

Medtronic Urges 8th Circ. To Back Its Transfer Pricing Method

June 6, 2024 06:21 PM

Oil Cos. Stifle Bids For Tax Transparency, SEC Letters Show

June 5, 2024 03:22 PM

Win May Embolden IRS Use Of Economic Substance Doctrine

June 4, 2024 11:54 AM

Luxembourg Candidate Calls To End EU Tax Unanimity Rule

May 31, 2024 07:41 PM

3M Tells 8th Circ. IRS Used Invalid Regs For $24M Allocation