Transfer Pricing

By Natalie Olivo

The Internal Revenue Service finalized slightly fewer advance pricing agreements for U.S. multinational corporations in 2024 following a record high in the previous year, according to an agency report released Thursday.

By Kevin Pinner

Pharmaceutical giant Pfizer had no taxable profits in its largest market, the U.S., after booking all its income in jurisdictions including Puerto Rico, Singapore and Ireland, according to a Senate Finance Committee report prepared by panel Democrats that was released Thursday.

By Natalie Olivo

Three major accounting firms have asked the Eleventh Circuit to reverse a U.S. Tax Court decision affirming the IRS' change to Coca-Cola's intercompany pricing, which led to a $2.7 billion tax bill, arguing the agency's conduct was unsupported and unjustified.  

By Natalie Olivo

U.S. multinational corporations have welcomed the option of a simplified transfer pricing approach under an international tax framework known as Amount B, but uncertainties linger about how the rules will ultimately shake out on a technical level both domestically and globally.

By David Hansen

Three industry groups asked the Eleventh Circuit to reverse a U.S. Tax Court decision affirming that the Internal Revenue Service could raise Coca-Cola's taxes by $2.7 billion, saying in friend-of-the-court briefs that the IRS acted arbitrarily in hiking the Atlanta-based beverage giant's tax liability.

By Kevin Pinner

Switzerland and Zimbabwe signed an agreement Wednesday for a treaty to avoid double taxation of income, an expansion of the Swiss treaty network in southern Africa that has been welcomed by cantons and businesses, according to Switzerland's competent authority.