Transfer Pricing

Top News

Pillar 1 Ratification Will Be Difficult, EU Official Says

By Bengt Ljung

A top European Commission official said he expects participating jurisdictions to sign a convention to implement the OECD's Pillar One plan for reallocating taxing rights in June as planned, but he admitted that subsequent ratification of the treaty will be difficult.

EU Parliament Committee Wants Transfer Pricing Law Sooner

By Todd Buell

A committee of the European Parliament said Thursday that it wants proposed new transfer pricing rules to enter into force one year earlier than currently planned.

Low Revenue May Drive US To Rethink Anti-Erosion Tax

By Dylan Moroses

The base erosion and anti-abuse tax has been relatively easy to avoid without significant legal risk, tax professionals told Law360, a result that may prompt lawmakers to consider revising or replacing the provision as other major parts of the Tax Cuts and Jobs Act expire at the end of 2025.

Medtronic Urges 8th Circ. To Undo Transfer Pricing Ruling

By Anna Scott Farrell

Medical device company Medtronic asked the Eighth Circuit on Friday to overturn a decision rejecting its pricing method for licensing intellectual property to its Puerto Rican affiliate, saying in the long-running case that Medtronic hadn't used the intercompany arrangement to underreport its income.

Manufacturers Back 3M In 8th Circ. Transfer Pricing Case

By David Hansen

The National Association of Manufacturers joined the chorus of business groups supporting 3M, asking the Eighth Circuit to throw out transfer pricing regulations that allow the Internal Revenue Service to reallocate income to U.S. group members even when foreign laws prohibit outbound payments.

Chamber, Others Back 3M In Transfer Pricing Appeal

By David Hansen

The Eighth Circuit should set aside transfer pricing regulations from the U.S. Treasury Department that reallocated $23 million of income from 3M's Brazilian affiliate to the parent company, three trade associations told the court in amicus briefs.


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

February 14, 2024 05:57 PM

Tech Group Backs 3M In 8th Circ. Transfer Pricing Appeal

February 13, 2024 08:15 PM

Think Tank Says US Should Undermine OECD Global Tax Deal

February 8, 2024 07:00 PM

3M Tells 8th Circ. IRS Used Invalid Regs To Allocate Income

February 7, 2024 06:42 PM

IRS Memo Highlights Tensions In Arm's-Length Loan Pricing

February 2, 2024 05:00 PM

Eaton Asks Court To Agree To Block IRS Summons

January 30, 2024 05:12 PM

India's APA Network Rivals Germany And China, Report Says

January 29, 2024 06:17 PM

Int'l Pricing Method Much Faster Than Others, Report Says

January 26, 2024 02:57 PM

HMRC Transfer Pricing Inquiries Took 5 Months Longer

January 26, 2024 01:43 PM

Biz Lobby Urges That BEFIT Wait On Stable Global Tax Rules

January 23, 2024 06:21 PM

Chile Aims To Rework Anti-Avoidance And CFC Rules

January 19, 2024 04:41 PM

UN Could Further OECD's Progress In Global Tax Diplomacy

January 16, 2024 06:44 PM

UK Businesses Favor Aligning Transfer Pricing With OECD

January 9, 2024 06:34 PM

Global Min. Tax Expected To Halve Profit Shifting, OECD Says

January 5, 2024 11:46 AM

EU Transfer Proposal Risks Double Taxation, Biz Group Says

January 5, 2024 04:01 PM

Eaton Corp. Need Not Heed IRS Summons, Judge Advises

January 2, 2024 01:50 PM

Group Status Germane To Adjusting Loan Rates, IRS Says

January 1, 2024 08:02 AM

Federal Tax Cases To Watch In 2024

January 1, 2024 08:02 AM

International Tax Policy To Watch In 2024

January 1, 2024 08:02 AM

International Tax Cases To Watch In 2024

December 15, 2023 07:32 PM

Tax Court's Medtronic Method Violates Regs, US Tells 8th Circ.