Transfer Pricing

Top News

Eaton Says Court Improperly Required Int'l Employee Evals

By David Hansen

An Ohio federal court should reconsider its decision that multinational power management company Eaton must disclose the personnel records of its foreign employees that were requested by the Internal Revenue Service in a transfer pricing investigation, the company told the court.

Mining Co. Entity Can't Deduct Loan Interest, UK Court Says

By Kevin Pinner

A U.S. mining company's entity in the U.K. that was created to save taxes through the acquisition of a Texas-based firm cannot overturn the Upper Tribunal's decision that its U.K tax deductions weren't deserved, according to a Court of Appeal judgment.

Groups Push Back On Stock Buyback Tax Test's Scope

By Jack McLoone

The U.S. Treasury Department's proposed stock buyback tax rules go too far in trying to assess whether the main purpose of a U.S. subsidiary's funding purchase of its foreign parent's stock is to avoid the tax, two groups said in comments released Wednesday.

Compliance Costs Outweigh Min. Tax Gains, Biz Reps Say

By Kevin Pinner

Multinational businesses are concerned that the burden of complying with the 15% global minimum tax outweighs any potential revenue gains associated with the burgeoning system, tax attorneys and a trade association representative said during a panel Tuesday.

EU Must Improve Country-By-Country Reporting, Group Says

By Jack McLoone

While there has been an uptick in voluntary country-by-country public disclosures, the large multinational corporations that do so make up just 2% of all large companies and account for less than 5% of global revenue and profits, necessitating further improvements, an EU-funded research group said Thursday.

Medtronic Urges 8th Circ. To Back Its Transfer Pricing Method

By Natalie Olivo

Medical device maker Medtronic reiterated Thursday its bid for the Eighth Circuit to revive its method for pricing intangible property that was licensed to a Puerto Rican affiliate, arguing the government's concessions show why the company's approach is more reliable.


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

June 6, 2024 06:21 PM

Oil Cos. Stifle Bids For Tax Transparency, SEC Letters Show

June 5, 2024 03:22 PM

Win May Embolden IRS Use Of Economic Substance Doctrine

June 4, 2024 11:54 AM

Luxembourg Candidate Calls To End EU Tax Unanimity Rule

May 31, 2024 07:41 PM

3M Tells 8th Circ. IRS Used Invalid Regs For $24M Allocation

May 30, 2024 04:29 PM

Later Pillar 1 Due Date Set For June As Tax Talks Wrap Up

May 29, 2024 05:14 PM

Colombian Court Affirms Fossil Fuel Tax Break Must Stay

May 22, 2024 12:57 PM

IRS Again Delaying Dividend Anti-Abuse Regs

May 20, 2024 05:16 PM

Turkey Will Introduce 15% Global Minimum Tax, Minister Says

May 17, 2024 04:59 PM

Transfer Pricing Deal Needed For Pillar 1, OECD Official Says

May 16, 2024 06:23 PM

Eaton Must Give Up Personnel Docs In Transfer Pricing Probe

May 14, 2024 06:41 PM

A Fifth Of Big Cos. Use Tax Transparency Standard, Org. Says

May 14, 2024 11:25 AM

Aussie Senate Faces Separation Of Promoter Penalty, Gas Tax

May 14, 2024 06:11 PM

Law Prof Comes To Treasury's Aid In 3M Transfer Pricing Fight

May 14, 2024 04:48 PM

Microsemi Calls IRS' Penalty Approval 'Woefully Inadequate'

May 11, 2024 04:13 PM

Gov't Urges 8th Circ. To Uphold 3M's $24M Pricing Adjustment

May 10, 2024 06:59 PM

5 Goals Gov'ts Have For The UN Tax Convention

May 8, 2024 02:31 PM

UN To Publish Draft Terms Of Reference For Tax Pact In June

May 7, 2024 06:00 PM

Industry Groups Suggest Changes To Aussie Reporting Rules

May 4, 2024 01:33 PM

IRS Seeks More Info On Purpose Test In Buyback Tax Regs

May 3, 2024 08:02 PM

US Resisting More Scoping On Amount B, Economist Says