Transfer Pricing

By Natalie Olivo

An Ohio federal judge denied Eaton Corp.'s bid to withhold foreign employee evaluations from the IRS, ruling Friday that the power management multinational's "astounding amount of effort" to fight disclosure has been a poor use of judicial resources.

By Jack McLoone

The Australian Taxation Office is looking for feedback on draft compliance guidance for corporations looking to use one of its new thin capitalization tests as they relate to cross-border financing arrangements, it said Thursday.

By Jack McLoone

Mexico's transfer pricing regime collected 19 billion pesos ($980 million) from large businesses last year, part of a trend that has seen the country's transfer pricing revenue more than triple over the past five years compared with the prior five-year period, its tax administration said.

By Kevin Pinner

Turkey, Azerbaijan and Jamaica don't allow taxpayers to use a transfer pricing method for baseline marketing and distribution activities known as Amount B, while Denmark's acceptance is limited, the OECD said Thursday in an update on the method's adoption.

By Kevin Pinner

The U.S. Tax Court erred by tossing the IRS' suggested method to price royalties for intangible property licensed by medical device maker Medtronic to a Puerto Rican affiliate because its products differed from those of comparable uncontrolled companies, a government attorney told the Eighth Circuit on Tuesday.

By Anna Scott Farrell

Eaton Corp. may withhold performance evaluations for three foreign employees from the IRS' investigation of Eaton's sale of intellectual property to an Irish affiliate, an Ohio federal judge decided Monday, saying the records are not important enough to the tax investigation to justify violating European privacy law.