Transfer Pricing

Top News

Gov'ts Widely Back Building Capacity Of Tax Authorities

By Kevin Pinner

Building the skills and capacities of tax authorities to implement international tax standards should be a central focus of global tax cooperation at the United Nations for governments to gain revenue, officials from the U.S., the African Group and many others said Monday.

Direct Hit On Tax Regs Unlikely If Justices Ditch Chevron

By Kat Lucero

A decision from the U.S. Supreme Court later this year on two cases challenging the so-called Chevron doctrine, which gives federal agencies wide latitude to interpret ambiguous laws, isn't likely to immediately affect tax regulations.

Colombia, Norway Aim To Harmonize UN And OECD Tax Work

By Kevin Pinner

Colombia and Norway are aiming to bring the best aspects of the OECD's tax work into negotiations at the United Nations while drafting a framework convention on global tax cooperation, officials said Friday during a conference in Paris.

Economists Suggest UN Tackle CFC Rules, Other Tax Policies

By Kevin Pinner

Governments should look at coordinating globally on controlled foreign corporation rules, economic substance requirements, financial transparency, excess profits taxes, inheritance taxes and wealth taxes in negotiations on the nascent United Nations tax convention, economists said Thursday at a conference in Paris.

IRS' Signals On Economic Substance Doctrine Draw Scrutiny

By Dylan Moroses

The Internal Revenue Service's recent legal success asserting a doctrine to invalidate transactions in tax law enforcement matters may embolden the government to broaden that argument's reach, and lawyers are concerned it doesn't properly apply to transfer pricing matters.

Siemens Asks Tax Court To Toss $1.2B IRS Bill

By David van den Berg

A U.S. subsidiary of German technology company Siemens is pushing the U.S. Tax Court to throw out $1.16 billion in tax deficiencies and penalties the IRS has imposed, saying the agency relied on invalid rules in denying a deduction.


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

March 12, 2024 05:24 PM

Tax Officials Say Data Needed To Coax Politicians Into Pillar 2

March 11, 2024 01:48 PM

Singapore Telecom Loses $201M Aussie Transfer Pricing Fight

March 8, 2024 05:31 PM

States Must Nix Worldwide Combined Reporting, COST Says

March 7, 2024 08:15 PM

Don't Let Pillar 1 Die, Policy Experts Tell House Tax Panel

March 5, 2024 06:49 PM

Goal Is Still For A Mandatory Amount B, Treasury Official Says

March 5, 2024 06:23 PM

Pillar 1 Would Have Cost US Gov't $1.4B In 2021, Study Says

March 1, 2024 02:34 PM

House Tax Panel To Prep Members On OECD Pillar 1

March 1, 2024 03:35 PM

UN Jabs OECD Over Human Rights Amid Tax Policy Tension

February 29, 2024 02:10 PM

Medtronic Says 3 Years Of Tax Returns Under IRS Audit

February 28, 2024 06:35 PM

SC Legislature OKs Standards For Transfer Pricing Matters

February 28, 2024 06:51 PM

Amgen Seeks Dismissal Of Investor Action Over $11B Tax Bill

February 26, 2024 06:27 PM

NZ Opts Out Of OECD's Amount B Transfer Pricing Rules

February 26, 2024 03:45 PM

More Analysis Needed In Lithium Pricing Guide, Groups Say

February 23, 2024 12:39 PM

Pillar 1 Ratification Will Be Difficult, EU Official Says

February 22, 2024 06:47 AM

EU Parliament Committee Wants Transfer Pricing Law Sooner

February 16, 2024 04:54 PM

Low Revenue May Drive US To Rethink Anti-Erosion Tax

February 16, 2024 05:05 PM

Medtronic Urges 8th Circ. To Undo Transfer Pricing Ruling

February 16, 2024 07:09 PM

Manufacturers Back 3M In 8th Circ. Transfer Pricing Case

February 15, 2024 06:58 PM

Chamber, Others Back 3M In Transfer Pricing Appeal

February 14, 2024 05:57 PM

Tech Group Backs 3M In 8th Circ. Transfer Pricing Appeal