Transfer Pricing

Top News

Eaton Needs To Cough Up Docs In IRS Probe, US Says

By Natalie Olivo

The U.S. government urged an Ohio federal judge to order power management multinational Eaton to produce records on certain European employees in response to an IRS investigation, arguing the company's contention the court lacks jurisdiction is "pure sophistry."

OECD Tax Chief Affirms Pillar 1 Progress As Deadline Passes

By Dylan Moroses

Negotiations continue on Pillar One at the Organization for Economic Cooperation and Development even after a deadline passed to release the final text of a multilateral convention to establish the project's taxing right known as Amount A, the director of the OECD's tax policy office said Monday.

EU Leaders Nominate President Von Der Leyen For 2nd Term

By Bengt Ljung

European Union leaders nominated European Commission President Ursula von der Leyen for a second term and named their picks for two other top jobs in the bloc that will steer European policy for the next five years, including tax policy and economic sanctions.

Aussie Betting Site Can't Duck Taxes Tied To News Corp. Sale

By Natalie Olivo

Trustees associated with an Australia-based gambling website owe capital gains taxes on the AU$31 million ($20.6 million) sale of the business to News Corp., an Australian court ruled, finding the parties lacked an affiliated relationship that could warrant an exception.

High Response To IRS Transfer Pricing Letters, Official Says

By David van den Berg

Most taxpayers that received letters from the Internal Revenue Service pursuant to a compliance campaign warning them of a transfer pricing issue have responded, an IRS official said Thursday.

New EU Chair Hungary Eyes Talks On Corp. Tax, But No Deals

By Bengt Ljung

Hungary, the incoming chair of meetings of European Union countries, plans to discuss energy taxation and several proposals on corporate taxation during the next six months but doesn't expect to reach any agreements, according to meeting agendas.


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 24, 2024 12:07 PM

EU States Turn Down Transfer Pricing Proposal, Report Says

June 24, 2024 05:39 PM

Loss Guidance Will Cover Pillar 2, IRS Official Says

June 17, 2024 06:05 PM

OECD Tax Plan Is Developing Nations' Best Choice, Prof Says

June 14, 2024 06:54 PM

Eaton Says Court Improperly Required Int'l Employee Evals

June 14, 2024 06:44 PM

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

June 12, 2024 05:41 PM

Groups Push Back On Stock Buyback Tax Test's Scope

June 11, 2024 05:41 PM

Compliance Costs Outweigh Min. Tax Gains, Biz Reps Say

June 6, 2024 01:50 PM

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

June 6, 2024 08:22 PM

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

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