Transfer Pricing

By Kevin Pinner

The European Union might be able to break an impasse with the U.S. in negotiations on taxing the digital economy by proposing a digital services tax with a wide base and a low rate, former OECD tax chief Pascal Saint-Amans told Paolo Gentiloni, the bloc's economics commissioner.

By Kevin Pinner

Developing countries should seek to add the United Nations' version of a minimum tax rule on payments to their bilateral tax treaties and to adopt corresponding laws domestically while approaching the OECD's more restrictive multilateral version with caution, an advocacy group said Tuesday.

By Jack McLoone

The Internal Revenue Service issued corrections Friday to proposed rules that outline when foreign taxes under the Pillar Two international minimum tax agreement could trigger long-standing U.S. rules that aim to prevent companies from what is known as double-dipping the same economic loss.

By Jack McLoone

Brazil is seeking public comments on proposed regulations related to its 2023 adoption of new transfer pricing rules, including the application of the international arm's-length standard, the country's revenue agency said Thursday.

By Kevin Pinner

The IRS declined a recommendation by its internal watchdog to require the agency's counsel to attend talks held with large multinational corporations by its appellate division, which agents say thwarts their ability to correctly enforce the economic substance doctrine, according to a report.

By Kat Lucero

Business groups urged the U.S. Treasury Department on Tuesday to remove what's known as the funding rule in forthcoming final regulations on the stock buyback tax, saying the provision would go beyond Congress' intentions for the levy, which aims to deter companies from giving outsize rewards to shareholders.