Transfer Pricing

Top News

Le Maire, Yellen Say Int'l Tax Deal Must Wrap Despite Holdouts

By Kevin Pinner

French finance minister Bruno Le Maire and U.S. Treasury Secretary Janet Yellen said Friday a deal to reform international taxation must be finished next month even without consensus among negotiators, according to France's Ministry of the Economy and Finance.

Balance Sheet Should Guide Scope Of APAs, IRS Official Says

By Molly Moses

Companies should look to bottom-line profits in determining which transactions they propose to cover in advance pricing agreements with the Internal Revenue Service, John Hughes, director of the agency's Advance Pricing and Mutual Agreement Program, told Law360 on Wednesday.

EU Tees Up Plan To Curb Tax Avoidance Via Shell Companies

By Kevin Pinner

The European Union will take action this year to limit the use of shell entities to avoid taxes, including by denying associated tax breaks to companies, the director of the bloc's tax authority said Wednesday.

Amgen Fights Income Allocations In $3.6B Tax Court Case

By Natalie Olivo

Drugmaker Amgen is challenging a $3.6 billion tax bill in the U.S. Tax Court, accusing the IRS of misattributing profits its Puerto Rican subsidiary earned while manufacturing biopharmaceutical products under intercompany license agreements.

EU Parliament Affirms Failure To Apply Tax Info-Sharing Rules

By Kevin Pinner

Ten European Union member countries failed to fully implement decadeold rules governing the automatic exchange of tax information to help prevent fraud and money laundering, according to a report adopted by the European Parliament on Thursday.

UK's Tax Gap Hits $48B, Fueled Heavily By Fraud, Studies Say

By Kevin Pinner

The United Kingdom's tax gap reached an estimated £35 billion ($48.2 billion) during the 2019-20 tax year, with tax fraud accounting for more than 40% of that total, according to a pair of studies published Thursday.


Expert Analysis

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.

US Advance Pricing Agreements, Amid COVID And Before

Steptoe & Johnson's Matthew Frank, former director of the U.S. Advance Pricing Agreement Program, shares insights from an Internal Revenue Service report revealing an uptick in APA completions amid the pandemic, discusses trends over the program's 30-year history, and suggests ways taxpayers and the IRS could bolster program participation.

Coke, 3M Tax Cases May Not Settle Blocked Income Debate

Even if the challenged U.S. Department of the Treasury regulation on blocked income is struck down by the U.S. Tax Court in the pending Coca-Cola and 3M cases, the obligations of a taxpayer that had, but failed to avail itself of, alternative means to secure payment will remain an open question, say Matthew Frank and Amanda Varma at Steptoe & Johnson.

MORE COVERAGE

September 15, 2021 02:30 PM

UN Tax Body Seeks Input On Agenda For Next 4 Years

September 10, 2021 06:43 PM

BEPS Concepts Echo 1923 Report, Australian Official Says

September 1, 2021 05:05 PM

Transfer Pricing Privacy Among Top Biz Worries, Tax Pros Say

August 31, 2021 12:31 PM

Malaysia Aims To Build Tax Revenue With 2022 Budget

August 30, 2021 05:07 PM

China Fast-Tracks Unilateral APAs, Leaves Details In Doubt

August 27, 2021 02:36 PM

German Transfer Pricing Rules Vex Companies, Auditors

August 26, 2021 08:26 PM

Heartburn Drug's Success Unforeseeable, Perrigo Tells Court

August 24, 2021 08:02 PM

UK Proposes Requiring Big Biz To ID Tax-Uncertainty Areas

August 20, 2021 02:52 PM

States' Transfer Pricing Push Raises Privacy Concerns

August 17, 2021 07:09 PM

Duff & Phelps Nabs Transfer Pricing Pro From EY

August 12, 2021 06:47 PM

Barbados Joins OECD's Global Tax Deal

August 10, 2021 02:30 PM

Irish Commissioner Backs Tax Agency's Records Denial To Co.

August 4, 2021 07:12 PM

IRS Asking Cos. About Virus' Effect On Japan APAs, Atty Says

August 3, 2021 05:32 PM

OECD Adds Categories, Countries To Transfer Pricing Database

July 30, 2021 06:51 PM

Poland Seeks Input On 'Historic' Tax Cuts

July 30, 2021 05:39 PM

Diageo Says It's Been Cleared In £277M EU State Aid Case

July 29, 2021 01:40 PM

Switzerland And Ethiopia Sign Double Taxation Agreement

July 28, 2021 07:00 PM

House Republican Asks Yellen To Keep FDII Deductions

July 28, 2021 05:46 PM

Retired Atty Sees More IRS Disputes Over Intercompany Loans

July 26, 2021 01:32 PM

Retired Amazon Lawyer Says TCJA Would Have Given IRS A Win