Transfer Pricing

Top News

IRS' Preliminary APA Screening Draws Mixed Reviews

By Dylan Moroses

Recently published IRS internal guidance detailing how the agency will screen advance pricing agreement requests has some tax practitioners concerned that prospective certainty may be more difficult to secure.

UAE Issues Transfer Pricing Records Rules For New Corp. Tax

By Matthew Guerry

The United Arab Emirates' Finance Ministry published a measure Thursday that outlines the transfer pricing documentation requirements for companies subject to the country's new corporate income tax.

Mayer Brown Adds Former IRS Int'l Tax Counsel

By David Hansen

Mayer Brown has a new partner in its Washington, D.C., office who served as an international tax counsel with the Internal Revenue Service, the firm announced.

Mineral Pricing Guidance Seeks To Curb Tax Avoidance

By Matthew Guerry

The Organization for Economic Cooperation and Development released mineral pricing guidance Wednesday that it drafted with another intergovernmental group to help developing nations tackle tax avoidance.

Pillar 2 Doesn't Lead To Double Taxation, IRS Atty Says

By Kevin Pinner

Double taxation is eliminated under model rules for the 15% global minimum tax plan known as Pillar Two, and declining to allow tax credits for the income-inclusion rule and undertaxed payment rule would be consistent with those rules, an IRS attorney said Tuesday.

Australian Gov't Proposes Levying 15% Global Minimum Tax

By Kevin Pinner

Australia's government proposed levying a 15% global minimum tax starting next year in its budget on Tuesday, saying the package is expected to raise AU$370 million ($250 million) in additional revenue through 2027.

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.


May 9, 2023 12:16 PM

OECD Transfer Pricing Guidance Bad Fit For EU, Critics Say

May 3, 2023 06:59 PM

Eaton Says IRS Wrongly Lowered Dividend Income By $193M

May 1, 2023 06:49 PM

Business Groups Urge Australia To Limit Global Tax Reporting

May 1, 2023 07:13 PM

IRS To Screen APA Requests, Offer Preliminary Reviews

April 28, 2023 07:26 PM

Int'l Transfer Pricing Guidelines Often Misapplied, Pros Say

April 27, 2023 10:32 PM

Coca-Cola Can't Escape Brazil Income Allocations, IRS Says

April 27, 2023 05:21 PM

Perrigo Says IRS Dropped $843M Tax Assessment

April 26, 2023 05:39 PM

Multilateral APAs May Increase In Frequency, IRS Official Says

April 25, 2023 06:19 PM

EU Tax Admins Need Better Cross-Border Data, Officials Say

April 24, 2023 04:50 PM

IRS Lacks Power To Allocate Blocked Income, Coca-Cola Says

April 20, 2023 07:20 PM

India's Top Court Says High Courts Can Probe Transfer Pricing

April 20, 2023 05:47 PM

Tax Policy Affects How Investment Is Made, Study Says

April 14, 2023 02:59 PM

Weekly Internal Revenue Bulletin

April 12, 2023 05:36 PM

US, Global Min. Taxes May Shake Up Deal Planning, Pros Say

April 11, 2023 07:37 PM

Developing Countries Still Skeptical Of Global Tax Plan's Value

April 3, 2023 02:03 PM

India Signs Record Number Of APAs In Fiscal Year

March 31, 2023 05:08 PM

Min. Tax Backstop Risks Destabilizing System, Experts Say

March 31, 2023 06:57 PM

Coca-Cola's Brazilian Income Is Still Blocked, Tax Court Told

March 29, 2023 06:20 PM

Some UN Experts See Value In Tool For Model Treaty Updates

March 29, 2023 04:22 PM

Pandemic Slowed APA Work In 2022, IRS Report Says