Transfer Pricing

Top News

Transfer Pricing Cases Collected £3.4B Last Year, HMRC Says

By Natalie Olivo

The U.K. brought in £3.4 billion ($4.6 billion) in additional revenue from transfer pricing cases from 2024-2025, nearly double the amount from the previous year, according to HM Revenue & Customs data released Wednesday.

Medtronic, IRS Pursuing Settlement In Transfer Pricing Case

By Molly Moses

Medtronic and the Internal Revenue Service are exploring the possibility of settling their U.S. Tax Court case, the parties said, which would avoid the need for a third trial on the pricing intangibles that the Minnesota-based company licensed to its Puerto Rican affiliate in 2005 and 2006.

Hewlett Packard To Fight IRS Transfer Pricing Adjustments

By Anna Scott Farrell

Hewlett Packard Enterprise Co. disagrees with transfer pricing adjustments by the IRS and will challenge the agency's efforts to increase its taxable income, the company said in a quarterly report released Tuesday.

11th Circ. Shouldn't Apply 3M Ruling To Coke, Gov't Says

By Molly Moses

The Eleventh Circuit should not apply the reasoning used by the Eighth Circuit in its October ruling for 3M Co. to allow Coca-Cola to indefinitely defer taxes it owes under IRS transfer pricing regulations, the U.S. government said Wednesday.

Belgium Loses Dispute With EU Over Foreign Tax Deductions

By Kevin Pinner

Belgium didn't correctly transpose a European Union law requiring states to allow taxpayers a deduction for taxes paid by controlled foreign corporations in their residence jurisdiction, the European Court of Justice said Thursday, disagreeing with a court adviser's views.

EU Trade Chief Urges Skeptical Lawmakers To Pass US Deal

By Kevin Pinner

The European Union's trade commissioner pleaded Tuesday with the bloc's lawmakers to ratify a trade deal with the U.S. next month, attempting to reassure skeptical lawmakers that President Donald Trump's administration has promised to respect its terms.


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

February 23, 2026 05:46 PM

EU Lawmakers Delay Vote On US Trade Deal Amid Uncertainty

February 20, 2026 03:44 PM

Full 8th Circ. Won't Revisit 3M's Win Against IRS

February 18, 2026 04:21 PM

Glencore Says It Paid $1B To HMRC Over Tax Disputes

February 17, 2026 02:42 PM

EU Seeks Feedback For Bill To Streamline Corporate Tax Laws

February 13, 2026 05:18 PM

Gov'ts To Explore Transfer Pricing Database For UN Tax Pact

February 11, 2026 02:22 PM

Tax Advisers Urge EU To Scrap Disclosure Rules

February 5, 2026 04:13 PM

UN Talks Aim To Identify Gaps On Harmful Tax Practices

February 3, 2026 03:00 PM

Virgin Islands Co. Wants Experts Barred In $11.5M Pricing Row

February 2, 2026 01:15 PM

EU Loses €14B In Taxes Annually From US Cos., Report Says

February 2, 2026 02:14 PM

OECD Amends Tax Treaty Manual To Up Dispute Resolution

February 2, 2026 08:13 PM

Int'l Tax In January: Global Min. Reached, Trade Deals Abound

January 29, 2026 05:48 PM

What Makes A Good Tax Court Expert? Economists Share Tips

January 29, 2026 05:51 PM

8th Circ.'s Ruling For 3M 'Makes No Sense,' Gov't Says

January 29, 2026 01:39 PM

Microsemi To Report $144M In Overseas Sales In Settlement

January 27, 2026 05:42 PM

Perrigo Overpaid Tax, Penalties By $89M, Court Finds

January 23, 2026 03:14 PM

UN Committee Releases Revised Tax Convention Template

January 22, 2026 04:58 PM

UN Committee Floats Draft For Taxing Cross-Border Services

January 16, 2026 02:49 PM

Spain, US Spell Out Tax Treaty Arbitration Process

January 15, 2026 05:17 PM

EU Should Use Tax Transparency For Public Bids, Report Says

January 15, 2026 07:43 PM

GM Unit's Transfer Pricing Doesn't Affect VAT, Adviser Says