Transfer Pricing

Top News

Int'l Pricing Pact Guidance Is Coming Soon, IRS Official Says

By Natalie Olivo

Updated Internal Revenue Service guidance that would help multinational corporations pursue advance pricing agreements will likely be released in a few months, an agency official said Tuesday.

Questions Loom Over China's Pillar 2 Participation

By Dylan Moroses

Practical and political problems surrounding the Organization for Economic Cooperation and Development's 15% global minimum corporate tax raise questions about how China and its biggest companies could undermine that regime.

India Signs Record Amount Of Advance Pricing Agreements

By Jack McLoone

India's Central Board of Direct Taxes entered into a record 125 advance pricing agreements with Indian taxpayers in fiscal year 2023-24, a 31% increase compared with the previous year, the authority said.

UN Should Eye Unitary Taxes, DSTs For Tax Pact, Report Says

By Kevin Pinner

Governments should use the United Nations tax convention as an opportunity to advance the overhaul of nexus away from transfer pricing and toward formulary apportionment, including digital services taxes, to achieve unitary taxation on corporate profits, scholars at the Brookings Institution said Friday in a report.

Transfer Pricing And Dancing: Recalling KPMG's Sean Foley

By Molly Moses

Sean Foley, who died suddenly in September, was a devoted husband, father, brother and friend and a brilliant colleague. He was one of the world's top experts in an area of international tax known as transfer pricing, where he became the global leader of KPMG's practice.

Aussie Tax Office Misses Transfer Pricing Review Goals

By Jack McLoone

In each of the past two years, the Australian Taxation Office came up short of its goal to review every use of transfer pricing for related party debt made by entities included in two major economic categories, a government audit revealed Wednesday.


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

April 16, 2024 06:18 PM

3 Key Takeaways From The IRS' Latest Pricing Pact Snapshot

April 15, 2024 07:34 PM

8th Circ. Urged To Revive IRS' Pricing For Medtronic

April 10, 2024 05:16 PM

EU Parliament Wants Transfer Pricing Rules To Apply Sooner

April 10, 2024 04:01 PM

IRS' DOJ Referral Rules 'A Disaster,' Sen. Whitehouse Says

April 9, 2024 07:51 PM

Treasury Proposes Long-Awaited Stock Buyback Tax Rules

April 5, 2024 01:48 PM

Contrasts Emerge Between Taiwan Tax Bill, Regular Treaties

April 4, 2024 06:29 PM

IRS Penalties Proper In $11B Amgen Dispute, Tax Court Says

April 3, 2024 07:19 PM

IRS Says $28M In Fines Against Microsemi Adhered To Rules

April 3, 2024 05:57 PM

McDermott Adds Ex-Baker McKenzie Tax Pro In Chicago

April 1, 2024 06:37 PM

US Support For Pillar 1 Still In Question After House Inquiry

March 29, 2024 06:31 PM

APA Work Doubled In 2023, IRS Report Says

March 27, 2024 06:31 PM

Czech Transfer Pricing Audits Boost Tax Base By $248M

March 26, 2024 07:00 PM

Adjusting To Amount B's Rules May Bring Growing Pains

March 25, 2024 02:05 PM

EU Court Asked To Rule On VAT On Transfer Pricing Payment

March 22, 2024 06:50 PM

Stock Buyback Tax Regs Imminent, Treasury Official Says

March 21, 2024 06:27 PM

UN Could Enhance Global Tax Agenda Setting, Officials Say

March 21, 2024 04:28 PM

Wyden Probes Swiss Bank's Ties To Billionaire Under Scrutiny

March 19, 2024 06:55 PM

UN Experts Aim To Finalize Tool For Model Treaty Updates

March 19, 2024 04:39 PM

OECD Deputy Tax Director To Leave Post In June

March 18, 2024 05:43 PM

Gov'ts Widely Back Building Capacity Of Tax Authorities