Transfer Pricing

Top News

Former Head Of MTC, Tenn. DOR Reflects On Years In SALT

By Maria Koklanaris

Joe Huddleston has had a hand in virtually every major issue in the state and local tax world for decades, whether during his tenure at the Tennessee Department of Revenue, the Multistate Tax Commission or the Federation of Tax Administrators. Now retired, he spoke to Law360 about his many roles and his influence in the field.

Australian Tax Transparency Rules Could Set Benchmark

By Natalie Olivo

Australian lawmakers recently enacted legislation that requires large multinational corporations to publicly disclose their worldwide business operations and tax information with an unprecedented level of scope and detail, which advocates say could set a global standard for corporate transparency.

US Guidance On Amount B Carries Potential For Disputes

By Dylan Moroses

Recent IRS guidance on a simplified and streamlined transfer pricing method for certain cross-border transactions, known as Amount B, suggests rulemakers want feedback on how it would work if it were made mandatory, but that approach could lead to controversy without global cooperation.

Australia Gives Guidance On Foreign-Funded Construction

By Jack McLoone

The Australian Taxation Office laid out a number of key areas that private companies receiving foreign funding from a related party for property or construction projects need to be aware of in order to not run afoul of the country's transfer pricing rules.

Still No Unanimous Path Forward On Amount B, OECD Says

By Jack McLoone

The Organization for Economic Cooperation and Development has still not found a path to an agreement on Pillar One's Amount B, which is designed to streamline the pricing of certain baseline marketing and distribution activities, with conversations being held up by possible "inappropriate outcomes," the OECD said Monday.

Sri Lanka Publishes Advance Pricing Agreement Guidance

By Jack McLoone

Sri Lanka's Inland Revenue Department published guidance for those interested in entering advance pricing agreements, including eligibility requirements and the steps of the confirmation process.


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

January 1, 2025 08:01 AM

Top Federal Tax Cases To Watch In 2025

January 1, 2025 08:01 AM

Top International Tax Cases To Watch In 2025

December 18, 2024 03:19 PM

Upcoming IRS Regs Will Have Optional Amount B Pricing

December 13, 2024 11:18 AM

Loper Bright May Influence Tax Less, IRS Chief Counsel Says

December 12, 2024 01:14 PM

Mexico To Join Int'l Pricing Program In 2025, Official Says

December 12, 2024 04:19 PM

IRS Hopes To Issue Amount B Pricing Guidance Within Weeks

December 5, 2024 05:35 PM

OECD Removes Application Deadline For Int'l Pricing Program

December 5, 2024 05:32 PM

Australia Mulling More Country-By-Country Reporting Advice

December 5, 2024 04:10 PM

Dutch Gov't Will Not Adopt Amount B Pricing Framework

December 2, 2024 04:00 PM

Australia Passes Public Country-By-Country Reporting

November 27, 2024 04:50 PM

UN Approves Start Of Formal Talks On Global Tax Convention

November 18, 2024 04:07 PM

6th Circ. Pauses IRS Summons For Eaton Worker Docs

November 18, 2024 01:52 PM

HMRC's £167M Charges To Reuters Group Deemed Lawful

November 15, 2024 03:02 PM

OECD Dispute Resolution Caseload Drops For First Time

November 7, 2024 05:57 PM

EU's Anti-Tax Avoidance Rules Underperforming, Group Says

November 7, 2024 12:10 PM

IRS To Hold Hearing On Dual Consolidated Loss Regs

November 5, 2024 04:03 PM

Australia Clarifies Thin Capitalization Rules Interactions

November 1, 2024 05:37 PM

NOL Rules May Retain Favorable Approach, IRS Counsel Says

October 31, 2024 06:29 PM

Treasury Using Help To Clear Pillar 1 'Logjam,' Official Says

October 31, 2024 06:03 PM

Oracle Can't Pause $166M Royalty Cases In Australia