Transfer Pricing

Top News

OECD Combines Past Updates In Transfer Pricing Guidance

By Natalie Olivo

The Organization for Economic Cooperation and Development released updated transfer pricing guidelines Thursday that consolidate earlier revisions to separate pieces of guidance, including how to use a method for splitting profits and how to handle hard-to-value intangible assets.

Australia To Review Advance Pricing Agreement Program

By Kevin Pinner

Australia on Wednesday said the nation's program for negotiating advance pricing agreements is undergoing a review this year to assess whether it's providing the right service for all taxpayers and preventing transfer pricing risk as efficiently as possible.

International Tax Cases To Watch In 2022

By Natalie Olivo

Courts will continue grappling this year with high-stakes cases brought by major U.S. multinationals that have accused federal tax authorities of overstepping, with disputes including FedEx's challenge to repatriation regulations and Facebook's fight against multibillion-dollar adjustments to its tax bill. Here, Law360 looks at eight key international tax cases to follow in 2022.

Amazon Shareholders Ask For Country-By-Country Tax Reports

By Dylan Moroses

Two major shareholders of Amazon have asked the e-commerce giant to begin reporting tax information country by country in light of a historic global tax deal reached in October, according to a statement from the shareholders' advisory firm.

Aussie Court Rejects Loan Terms Of Singapore Co.'s Affiliates

By Molly Moses

An Australian subsidiary of a Singapore telecom can't claim tax deductions for interest payments made to another subsidiary because independent parties wouldn't have agreed to the arrangement, the Federal Court of Australia held Friday.

EU Digital Tax To Be Scrapped For Good, Official Confirms

By Matt Thompson

A proposed digital levy that was intended to contribute to the European Union's budget and was recently suspended is now due to be removed permanently from the EU's legislative agenda, a senior European Commission official confirmed to Law360.


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

December 3, 2021 06:54 PM

Canadian Justices Toss Taxes On Company's Foreign Affiliate

December 2, 2021 07:30 PM

Netflix To Pay Australia Tax On Subscriber Revenue, Co. Says

December 1, 2021 03:59 PM

HMRC Eyes Tweaks To Corp. Tax System Following Review

December 1, 2021 10:22 PM

No Tax Court Redo For Coke In $3.3B Transfer Pricing Row

November 30, 2021 05:56 PM

OECD Deal Timeline Too Short, Ex-GOP Tax Counsels Find

November 23, 2021 06:00 PM

Shell Companies Detrimental To Netherlands, Gov't Reports

November 22, 2021 06:20 PM

Transfer Pricing Disputes Rising While Others Fall, OECD Says

November 17, 2021 06:42 PM

US, EU Won't Budge On Tax Deal's Scope, Irish Lobbyist Says

November 17, 2021 05:31 PM

Contrast In GILTI Plans, Int'l Tax Deal May Muddle Compliance

November 12, 2021 03:17 PM

MTC Defends Transfer Pricing Panel's Info-Sharing Agreement

November 12, 2021 07:36 PM

Zimmer Biomet Agrees To Deal In $209M Transfer Pricing Case

November 9, 2021 12:41 PM

IRS Seeks Input On Form For Transfer Reporting Extensions

November 8, 2021 07:13 PM

Bank Can't Claim $102M Loss, Canada's Tax Court Says

November 2, 2021 07:19 PM

Tax Court Won't Rule On Facebook Transfers Until After Trial

October 30, 2021 05:46 PM

Biden, Yellen Hail G-20's Endorsement Of Global Minimum Tax

October 28, 2021 04:30 PM

La. Will Launch Transfer Pricing Managed Audit Program

October 27, 2021 07:52 PM

Coca-Cola Is Too Late To Fight $3.3B Tax Court Loss, IRS Says

October 22, 2021 05:21 PM

Nova Scotia Bank's $6.5M Tax Interest Appeal Tossed

October 18, 2021 10:27 PM

IRS Witness Disputes Reseller Benchmark In Facebook Trial

October 18, 2021 04:51 PM

30 Nations Late In Meeting Global Tax Reporting Standards