Transfer Pricing

Top News

UN Jabs OECD Over Human Rights Amid Tax Policy Tension

By Dylan Moroses

Inquiries made by United Nations officials to the Organization for Economic Cooperation and Development about how the OECD's international tax plan affects the rights of individuals indicate continuing tension between the two intergovernmental bodies that shows little sign of easing.

House Tax Panel To Prep Members On OECD Pillar 1

By Dylan Moroses

Neither Republicans nor Democrats on the House Ways and Means Committee have opined much about the OECD profit reallocation plan known as Pillar One, but they will gain valuable information during an upcoming subcommittee meeting, a tax staffer for the panel said Friday.

Medtronic Says 3 Years Of Tax Returns Under IRS Audit

By Jack McLoone

Three years of medical device company Medtronic's federal income tax returns are being audited by the Internal Revenue Service, the company said in a U.S. Securities and Exchange Commission filing.

SC Legislature OKs Standards For Transfer Pricing Matters

By Maria Koklanaris

South Carolina lawmakers passed a bill Wednesday that would impose additional standards for when the state or a business can assert alternative apportionment when evaluating transfer pricing matters.

Amgen Seeks Dismissal Of Investor Action Over $11B Tax Bill

By David Hansen

Amgen had no obligation to disclose specific amounts of proposed adjustments to its taxes, the company told a New York federal court as it again demanded dismissal of a proposed class action alleging the company hid a $10.7 billion tax bill from investors.

More Analysis Needed In Lithium Pricing Guide, Groups Say

By Kevin Pinner

Functional analysis of multinational corporate groups should be included in a list of factors that could highly influence market prices within a transfer pricing framework for lithium, industry groups and accountants told the OECD in letters published Monday.


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 26, 2024 06:27 PM

NZ Opts Out Of OECD's Amount B Transfer Pricing Rules

February 23, 2024 12:39 PM

Pillar 1 Ratification Will Be Difficult, EU Official Says

February 22, 2024 06:47 AM

EU Parliament Committee Wants Transfer Pricing Law Sooner

February 16, 2024 04:54 PM

Low Revenue May Drive US To Rethink Anti-Erosion Tax

February 16, 2024 05:05 PM

Medtronic Urges 8th Circ. To Undo Transfer Pricing Ruling

February 16, 2024 07:09 PM

Manufacturers Back 3M In 8th Circ. Transfer Pricing Case

February 15, 2024 06:58 PM

Chamber, Others Back 3M In Transfer Pricing Appeal

February 14, 2024 05:57 PM

Tech Group Backs 3M In 8th Circ. Transfer Pricing Appeal

February 13, 2024 08:15 PM

Think Tank Says US Should Undermine OECD Global Tax Deal

February 8, 2024 07:00 PM

3M Tells 8th Circ. IRS Used Invalid Regs To Allocate Income

February 7, 2024 06:42 PM

IRS Memo Highlights Tensions In Arm's-Length Loan Pricing

February 2, 2024 05:00 PM

Eaton Asks Court To Agree To Block IRS Summons

January 30, 2024 05:12 PM

India's APA Network Rivals Germany And China, Report Says

January 29, 2024 06:17 PM

Int'l Pricing Method Much Faster Than Others, Report Says

January 26, 2024 02:57 PM

HMRC Transfer Pricing Inquiries Took 5 Months Longer

January 26, 2024 01:43 PM

Biz Lobby Urges That BEFIT Wait On Stable Global Tax Rules

January 23, 2024 06:21 PM

Chile Aims To Rework Anti-Avoidance And CFC Rules

January 19, 2024 04:41 PM

UN Could Further OECD's Progress In Global Tax Diplomacy

January 16, 2024 06:44 PM

UK Businesses Favor Aligning Transfer Pricing With OECD

January 9, 2024 06:34 PM

Global Min. Tax Expected To Halve Profit Shifting, OECD Says