Transfer Pricing

Top News

EU Still Hopes For Pillar 1 Despite Doubts

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.

UK Adds Over A Dozen Countries To Global Minimum Tax List

By Josh White

HM Revenue & Customs added more than a dozen countries to the list of states implementing Pillar Two's global minimum tax rules, the tax authority said Wednesday.

3rd Time's The Charm? The Tax Court's Odyssey In Medtronic

By Molly Moses

A U.S. Tax Court judge has been sent back to the drawing board once again in the long-running transfer pricing litigation brought by Medtronic, raising questions about how much weight the court must give to IRS transfer pricing regulations and how much authority it has to go its own way.

Indian Gov't Report Floats Fixed Profit Rates For Foreign Cos.

By Kevin Pinner

India should revise its permanent establishment rules by introducing an optional scheme to assign fixed profit rates by industry or business model, which would reduce litigation by foreign businesses over profit attribution methods, a government think tank said Friday.

Mining Cos. Warn Of OECD Guidance's Transfer Pricing Risks

By Josh White

Mining companies and other stakeholders raised concerns over transfer pricing risks and possible tax disputes arising from proposed guidance on pricing copper exports, according to documents published by the Organization for Economic Cooperation and Development.

Getting It Right: An Economist On Transfer Pricing

By Molly Moses

Michael McDonald, who retired from EY last month, spent most of his career at the U.S. Treasury Department, working on rules governing how related companies should calculate the value of intangible assets transferred between them, then later contributed to the massive rewrite of international tax rules by the OECD in 2015. McDonald reflected on both projects in an interview with Law360.


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

October 1, 2025 12:54 PM

8th Circ. Reverses IRS Win In 3M Transfer Pricing Case

September 29, 2025 02:32 PM

Calif. Tech Retailer Challenges $3.5M Bill In Tax Court

September 26, 2025 04:05 PM

Audits Focused On Profit Shifting, Transfer Pricing, ATO Says

September 26, 2025 03:06 PM

Microsemi, IRS Reach Deal To Settle Transfer Pricing Dispute

September 25, 2025 08:02 PM

Perrigo Mostly Beats US In $163M Tax Refund Dispute

September 23, 2025 05:09 PM

Albania Becomes 10th To Sign Min. Tax Payments Treaty

September 18, 2025 05:11 PM

Australia Sees Dip In Advance Pricing Agreements

September 15, 2025 04:45 PM

McKesson Too Late To Fight IRS Cost-Share Rules, Gov't Says

September 9, 2025 07:05 PM

SC Panel Weighs Whether Tractor Supply Shifted Income

September 3, 2025 01:43 PM

Tax Court Must Reconsider Medtronic Pricing, 8th Circ. Says

August 29, 2025 01:58 PM

Apple Must Hand Swiss User's Records To IRS, Judge Rules

August 28, 2025 05:58 PM

Coke Says IRS Taking 'Extreme' Position In $2.7B Dispute

August 26, 2025 04:40 PM

Facebook Urges Tax Court To Toss IRS' Royalty Calculations

August 18, 2025 03:39 PM

IRS Accepting Applications To 2026 Real-Time Audit Program

August 14, 2025 05:07 PM

Developing Nations Disfavor Arbitration In UN Tax Convention

August 11, 2025 05:22 PM

Goodyear Facing Tax Adjustments Over Intercompany IP Sale

August 11, 2025 04:54 PM

6th Circ. Orders Eaton To Give Employee Records To IRS

August 11, 2025 06:21 PM

Gov'ts Mull Gross Basis Tax For Services In UN Convention

August 11, 2025 06:24 PM

Tax Court Backs IRS' Denial Of Whistleblower's Award Bid

August 6, 2025 05:48 PM

Biz Group Urges EU To Pursue Digital Tax, Limit Min. Tax