Transfer Pricing

Top News

OECD Removes Application Deadline For Int'l Pricing Program

By Dylan Moroses

The Organization for Economic Cooperation and Development said Thursday it has removed biannual deadlines for large multinational entities to apply for the International Compliance Assurance Program, a multilateral effort to resolve transfer pricing issues.

Australia Mulling More Country-By-Country Reporting Advice

By Jack McLoone

While the Australian Taxation Office is already working on guidance for the country's newly adopted public country-by-country reporting rules, it is looking for input on what other areas of the provision businesses may need assistance in interpreting.

Dutch Gov't Will Not Adopt Amount B Pricing Framework

By Natalie Olivo

The Dutch government announced that it will not apply a new international tax framework known as Amount B that is designed to streamline the pricing of certain cross-border operations, but it will accept the outcome when other countries apply it.

Australia Passes Public Country-By-Country Reporting

By Kevin Pinner

Multinational businesses with large operations in Australia are required to publicly disclose information about their operations in tax havens as designated by the government under a country-by-country reporting law that lawmakers adopted following a two-year saga over concerns about the data's confidentiality.

UN Approves Start Of Formal Talks On Global Tax Convention

By Kevin Pinner

The United Nations General Assembly voted Wednesday in favor of beginning formal negotiations on a global tax convention next year with the goal of finishing in 2027, a proposal that was led by the body's African bloc and won support from 125 countries.

6th Circ. Pauses IRS Summons For Eaton Worker Docs

By Anna Scott Farrell

The Sixth Circuit said Eaton Corp. doesn't have to comply with an IRS demand to produce performance reviews for its foreign employees until the appellate court decides whether to overturn a decision that the agency's transfer pricing investigation of the multinational power management company outweighed worker privacy concerns.


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

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

October 24, 2024 06:21 PM

IRS Forming Transfer Pricing Team To Aid Real-Time Audits

October 23, 2024 06:34 PM

Microsemi's Fines Mostly Adhered To Rules, Tax Court Says

October 22, 2024 07:09 PM

8th Circ. Judge Presses IRS On 3M Transfer Pricing Tax Ruling

October 21, 2024 06:30 PM

BDO Appoints Former HMRC Official, 3 Others To UK Offices

October 15, 2024 06:22 PM

Microsoft's Cost-Share Tax Arguments 'Deficient,' Mich. Says

October 11, 2024 05:59 PM

NJ Seeking Transfer Pricing Consultant For Audits, Litigation

October 10, 2024 05:16 PM

Pfizer Lone Holdout In Senate Pharma Tax Probe, Wyden Says

October 9, 2024 03:34 PM

3M Tax Ruling Must Fall Post-Chevron, Chamber Tells 8th Circ.

October 4, 2024 05:04 PM

Promise Of OECD's Payments Tax Treaty Called Into Question

October 3, 2024 06:04 PM

3M Tells 8th Circ. Chevron's End Dooms IRS In $24M Dispute

October 2, 2024 06:50 PM

BlackBerry's $17M In R&D Not Taxable, Canada Court Rules

October 1, 2024 06:44 PM

Amgen Must Face Suit It Misled Investors On $10.7B Tax Bill