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News (1655)
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March 04, 2019 APA Workbook Doesn't Advocate Profit Split Method, IRS Says
...Rather, the model is one "input" for helping determine the best transfer pricing method....
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March 01, 2019 APA Workbook Signals Deference To Profit Split Method
...While technically an arm's-length transfer pricing method, residual profit split, much more than the...
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March 01, 2019 OECD Taps Former Amazon Exec For Top Foreign Tax Position
...Pricing and Financial Transactions Division, the OECD has announced....
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February 22, 2019 Changes In US Tax Law Rattle Treaty Partners, Panelists Say
...pricing disputes....
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February 22, 2019 Arm's-Length Principle Not In Peril, Treasury Official Says
...pricing among the various affiliates in a way that the average rate does not," he said....
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February 22, 2019 Digital Tax Involves Some 'Surrender' Of Revenue, Atty Says
..."In your transfer pricing documentation, if you are going to have to allocate 10 percent of a marketing...
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February 21, 2019 Swiss Mining Co. Glencore Faces $680M UK Tax Assessment
...The company said the amounts relate to "formal transfer pricing, permanent establishment and diverted...
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February 20, 2019 ABB Unit Settles Tax Dispute For About 10 Cents On Dollar
...pricing for about $1.6 million....
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February 15, 2019 Leaving Arm's-Length Means Defining Hard Concepts, Panel Says
...., examined how the interpretation of the arm's-length principle — the international transfer pricing...
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February 14, 2019 OECD Aims For Digital Tax Bargain By May: Treasury Official
...pricing analysis of the value of marketing intangibles."...
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February 14, 2019 Belgian Tax Rulings Weren't State Aid, EU Court Finds
...The current design, with its transfer pricing rules, is simply not sustainable over the long term."...
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February 13, 2019 Bilateral APAs Will Be A Strategy In Japan, Specialists Say
...Multinational companies should turn to bilateral advance transfer pricing agreements with Japan due to...
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February 12, 2019 A Sneak Peek At Dutch Advance Ruling Practice
...Transfer Pricing Report, Jan. 30, 2019....
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February 11, 2019 Starbucks' Past Tax Practices May Derail Schultz Bid
... Company officials said the price had been determined using transfer pricing principles that...
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February 11, 2019 Armenia Joins OECD's Inclusive Framework
...pricing among units of multinational companies....
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February 06, 2019 OECD Continues Quest For Digital Tax Solution
...., nexus), and how much profit should be allocated to the business conducted there under transfer pricing...
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February 05, 2019 Perrigo Fights Judge's Denial Of IRS Report In $163M Tax Row
...But case law permits access to the IRS administrative file in transfer pricing proceedings because of...
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February 01, 2019 OECD Won't Adopt 'Radical' Tax Solutions: Treasury Official
...pricing and financial transactions division....
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February 01, 2019 OECD Signals It's Adding More Length To 'Arm's-Length'
...While this long-held approach is likely here to stay as an overall framework, transfer pricing guidelines...