Transfer Pricing

Top News

Checklist Could Help Simplify Global Tax Policy, OECD Says

By Kevin Pinner

A checklist of questions for global tax policymakers could help simplify the outcomes of their work, the OECD said in a Tuesday report to the Group of 20 nations.

Judge Questions Eaton's Role In Lowered Credit Rating

By Molly Moses

Tax Court Judge Albert Lauber questioned an expert for Eaton on Monday about how he arrived at a lowered credit rating for the U.S. company in a report he prepared in January 2013, shortly after it acquired an Irish-based global electrical products manufacturer and inverted.

Belgium Postpones Global Minimum Tax Filing Deadline

By Josh White

Belgium will extend the deadline for multinational companies to file their returns as part of the 15% global minimum corporate tax regime until June 2026, the finance ministry announced Monday.

IRS Expert Challenges Data Used In Eaton's Projections

By Molly Moses

An expert witness for the Internal Revenue Service questioned the financial projections prepared by Eaton Corp.'s experts Friday in U.S. Tax Court, saying the data they relied on wasn't available in 2012, when the company took on debt to acquire Ireland-based Cooper Industries, a global electrical products manufacturer, for $13 billion.

Eaton Witnesses Probed About Data Used For Credit Analysis

By Molly Moses

An accounting expert and a former Eaton Corp. official both advised the U.S. Tax Court on Thursday about the data used to establish the financial position of the U.S. company after its acquisition of Irish-based Cooper Industries in 2012.

8th Circ. Denies Medtronic's Bid To Rethink Pricing Ruling

By Natalie Olivo

The Eighth Circuit denied healthcare tech company Medtronic's request to reconsider the court's approach for pricing a licensing agreement with a Puerto Rican affiliate, leaving in place Wednesday a ruling that directed the U.S. Tax Court to give the Internal Revenue Service's method another look.


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

November 7, 2025 09:55 PM

Eaton Should Have Weighed Borrowing In Europe, Judge Says

November 5, 2025 08:22 PM

Judge Questions Transfer Of Eaton's $14B Foreign Asset

November 5, 2025 11:30 AM

Switzerland Adopts Tax Treaty With Zimbabwe

November 4, 2025 06:15 PM

3M Ruling Highlights Loper Bright's Reach In Axing Tax Regs

November 4, 2025 08:24 PM

Former Eaton CFO Says Bond Investors Needed Reassurance

November 3, 2025 08:31 PM

Eaton Debt Analysis Must Trace Distinct Steps, Tax Court Told

November 3, 2025 06:26 PM

Kenya Seeks Input On Regs For Min. Tax, Advance Pricing

October 31, 2025 03:12 PM

OECD Reports Sharp Uptick In Transfer Pricing Dispute Cases

October 31, 2025 05:06 PM

OECD Reports Rise In Failed Advance Pricing Agreements

October 28, 2025 03:07 PM

UN Committee Seeks Feedback On Tax Treaty, Dispute Ideas

October 22, 2025 05:52 PM

'The Right Facts' Can Reduce Cos.' Tariff Impacts, Atty Says

October 22, 2025 06:12 PM

US Among Few Places With Amount B Rules, OECD Reports

October 22, 2025 06:17 PM

Australia Issues Guidance For Minimum Tax Safe Harbor

October 21, 2025 01:05 PM

Medtronic Says 8th Circ. Wrongly Tossed Tax Court's Method

October 20, 2025 08:23 PM

G7 Deal Exempting US From Min. Tax Hurts Brazil, Prof Says

October 16, 2025 11:50 AM

EU Still Hopes For Pillar 1 Despite Doubts

October 15, 2025 01:32 PM

UK Adds Over A Dozen Countries To Global Minimum Tax List

October 8, 2025 06:59 PM

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

October 3, 2025 05:17 PM

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

October 3, 2025 02:10 PM

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