Transfer Pricing

Top News

OECD Mulling Gov't-Only Dispute Panels, US Official Says

By Dylan Moroses

The U.S. and OECD are considering how to compose review panels tasked with settling disputes under the global tax overhaul's reallocation of taxing rights given the broad support for limiting the panels to government officials, a Treasury official said Tuesday.

OECD Prepared To Tackle Taxing Rights, US Official Says

By Dylan Moroses

The next Organization for Economic Cooperation and Development consultation on its global tax deal will detail which jurisdiction will surrender taxing rights in the reallocation of those rights on highly profitable companies, a U.S. Treasury Department official said Monday.

UN Considering Multilateral Treaty For Digital Tax Models

By Kevin Pinner

The United Nations Tax Committee is looking at drafting a multilateral instrument for adopting new models to help countries preserve rights to tax global, digital firms whose economic presence isn't fairly reflected by permanent establishment tests, its secretary told Law360.

OECD Told Dispute Panels Must Include Gov't Officials Only

By Dylan Moroses

Government officials should be the only figures responsible for settling cross-border disputes that might result from the reallocation of taxing rights under the Organization for Economic Cooperation and Development's international tax rewrite, industry groups told the organization.

New Jersey Rolls Out Transfer Pricing Tax Resolution Program

By Paul Williams

New Jersey will offer taxpayers a voluntary transfer pricing agreement program to resolve potential tax controversies resulting from pricing disputes stemming from intercompany transactions for open tax years, the state Division of Taxation announced Thursday.

Tax Talks Gave The Wealthy A Chance To Share, Experts Say

By Kevin Pinner

The Organization for Economic Cooperation and Development's process for overhauling the international tax system created a chance for governments in wealthier countries to share taxing rights, several experts from developing countries said during a panel Tuesday.


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.

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