Transfer Pricing

Top News

Denmark Floats Edits To OECD Tax Standards Adoption

By Jack McLoone

The Danish Ministry of Taxation is seeking feedback on proposed edits to measures tied to its implementation of the OECD's standards, such as the adoption of new administrative guidance for the global minimum tax and tweaks to its transfer pricing procedures.

US Drops Out Early From UN Global Tax Convention Talks

By Kevin Pinner

The U.S. government will no longer participate in United Nations negotiations aimed at drafting a framework convention on international tax cooperation, intends to reject the outcome and welcomes other countries to join in its opposition, a U.S. diplomat said.

Indian Budget Would Simplify Transfer Pricing, Cut $11.5B

By Natalie Olivo

The Indian government floated a process to streamline the pricing of intercompany cross-border transactions as part of a wide-ranging budget proposal that includes one trillion rupees ($11.5 billion) in tax cuts.

UN Tax Pact Should Aim For Unitary Taxation, Economists Say

By Kevin Pinner

The United Nations' global tax convention should strengthen the ability of countries to tax nonresident multinational corporate service providers as unitary global entities, standardize withholding taxes on deemed profits and adapt existing model rules for digital services, a group of economists said Monday.

OECD Details Documents Needed For Int'l Pricing Program

By David Hansen

The Organization for Economic Cooperation and Development released more details Tuesday on the information that multinational entities must disclose when applying for the group's International Compliance Assurance Program, a multilateral effort to resolve transfer pricing issues.

Transfer Pricing Brought In £1.8B In Tax Last Year, HMRC Says

By Jack McLoone

U.K. transfer pricing activities brought in nearly £1.8 billion ($2.2 billion) in additional tax revenue in the 2023-24 tax year, HM Revenue & Customs said Monday, an over £150 million increase from the year prior despite a decrease in overall inquiries.


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

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January 24, 2025 12:38 PM

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January 17, 2025 06:58 PM

US Guidance On Amount B Carries Potential For Disputes

January 15, 2025 05:50 PM

Australia Gives Guidance On Foreign-Funded Construction

January 13, 2025 03:14 PM

Still No Unanimous Path Forward On Amount B, OECD Says

January 9, 2025 02:17 PM

Sri Lanka Publishes Advance Pricing Agreement Guidance

January 1, 2025 08:01 AM

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January 1, 2025 08:01 AM

Top International Tax Cases To Watch In 2025

December 18, 2024 03:19 PM

Upcoming IRS Regs Will Have Optional Amount B Pricing

December 13, 2024 11:18 AM

Loper Bright May Influence Tax Less, IRS Chief Counsel Says

December 12, 2024 01:14 PM

Mexico To Join Int'l Pricing Program In 2025, Official Says

December 12, 2024 04:19 PM

IRS Hopes To Issue Amount B Pricing Guidance Within Weeks

December 5, 2024 05:35 PM

OECD Removes Application Deadline For Int'l Pricing Program

December 5, 2024 05:32 PM

Australia Mulling More Country-By-Country Reporting Advice

December 5, 2024 04:10 PM

Dutch Gov't Will Not Adopt Amount B Pricing Framework

December 2, 2024 04:00 PM

Australia Passes Public Country-By-Country Reporting

November 27, 2024 04:50 PM

UN Approves Start Of Formal Talks On Global Tax Convention

November 18, 2024 04:07 PM

6th Circ. Pauses IRS Summons For Eaton Worker Docs

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