Transfer Pricing

By Molly Moses

Multinational companies with U.S. distributors that typically bear fewer business risks and earn low profit margins may be able to mitigate the effect of U.S. tariffs on their business as a whole by having a foreign principal bear the tariff costs, an attorney said Wednesday.

By Kevin Pinner

The U.S. is a significant exception to a swath of countries, including China, Japan and the U.K., that lack domestic rules allowing companies to use a transfer pricing method for baseline marketing and distribution activities known as Amount B, the OECD reported Wednesday.

By Kevin Pinner

Australia released guidance Wednesday detailing when companies can forgo detailed top-up tax calculations for a jurisdiction under a safe harbor for the 15% global minimum tax that is based on country-by-country reporting.

By Molly Moses

The Eighth Circuit's rejection of the U.S. Tax Court's latest ruling on the pricing of Medtronic intangibles placed unnecessary restrictions on the court's unspecified method addressing such assets transferred to Puerto Rico, the company argued as it asked the circuit court to rethink its decision.

By Molly Moses

Latin American countries, especially Brazil, are concerned that the deal announced by the Group of Seven countries in June exempting U.S. multinationals from a globally agreed 15% minimum tax gives the U.S. an unfair advantage over them, a professor at University of Antwerp said Monday.

By Josh White

The European Union's best chance for resolving how to tax the digital economy is still to use the OECD's Pillar One rather than unilateral measures that risk disputes, the EU's tax director told the European Parliament's tax committee Thursday.