Transfer Pricing

Top News

Eaton's Position On Parental Support Conflicting, Judge Says

By Molly Moses

Eaton is telling "different stories at different times" about the ability of its foreign parent company to step in and pay the U.S. company's debt obligations to third parties, Tax Court Judge Albert Lauber said in questioning one of the company's experts Friday.

Belgian Court Refers FATCA Data Case To EU's Top Court

By Josh White

A Brussels court referred a case to the Court of Justice of the European Union concerning whether transfers of U.S. taxpayer data breach EU privacy law, according to a court document released Thursday.

Judge Skeptical Implicit Support Worthless To Eaton Investors

By Molly Moses

A U.S. Tax Court judge closely questioned Thursday an expert for Eaton who said potential investors would not have counted on financial support from the company's parent in the event it couldn't meet its obligations after acquiring an Irish entity and inverting in 2012.

5 Takeaways From Eaton Trial On Acquisition Financing, Part 1

By Molly Moses

The first part of Eaton’s closely watched U.S. Tax Court trial over the company’s financing of a 2012 acquisition has wrapped up, and the judge's questions to witnesses during the first two and a half weeks reveal that he’s leaning the government’s way on at least one of the central questions in the case. Here, Law360 offers five takeaways from the trial held Nov. 3-19, then resuming Dec. 4.

Switzerland Delays Crypto Info Swaps With Tax Authorities

By Kevin Pinner

Switzerland will not automatically exchange information on cryptocurrency accounts with foreign tax authorities until at least 2027, although rules governing the exchanges are being adopted into law, the country's executive branch said Wednesday.

Profit Shifting Signs Persist Despite Waning, OECD Says

By Kevin Pinner

Signs of profit shifting by multinational companies remain persistent despite some abatement over the past several years, the Organization for Economic Cooperation and Development said Tuesday.


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

November 19, 2025 02:40 PM

OECD Releases Model Tax Treaty Updates For Amount B

November 19, 2025 01:23 PM

EU Tax Compliance Rules Raise €6.8B Annually, EC Finds

November 19, 2025 04:31 PM

Gov'ts Widely Back Mutual Agreement Procedure In UN Treaty

November 19, 2025 08:28 PM

Judge Unlikely To Find Eaton's Debt To Parent Wasn't Real

November 18, 2025 01:01 PM

Checklist Could Help Simplify Global Tax Policy, OECD Says

November 17, 2025 07:59 PM

Judge Questions Eaton's Role In Lowered Credit Rating

November 17, 2025 02:08 PM

Belgium Postpones Global Minimum Tax Filing Deadline

November 14, 2025 08:08 PM

IRS Expert Challenges Data Used In Eaton's Projections

November 13, 2025 09:28 PM

Eaton Witnesses Probed About Data Used For Credit Analysis

November 12, 2025 02:34 PM

8th Circ. Denies Medtronic's Bid To Rethink Pricing Ruling

November 7, 2025 09:55 PM

Eaton Should Have Weighed Borrowing In Europe, Judge Says

November 5, 2025 08:22 PM

Judge Questions Transfer Of Eaton's $14B Foreign Asset

November 5, 2025 11:30 AM

Switzerland Adopts Tax Treaty With Zimbabwe

November 4, 2025 06:15 PM

3M Ruling Highlights Loper Bright's Reach In Axing Tax Regs

November 4, 2025 08:24 PM

Former Eaton CFO Says Bond Investors Needed Reassurance

November 3, 2025 08:31 PM

Eaton Debt Analysis Must Trace Distinct Steps, Tax Court Told

November 3, 2025 06:26 PM

Kenya Seeks Input On Regs For Min. Tax, Advance Pricing

October 31, 2025 03:12 PM

OECD Reports Sharp Uptick In Transfer Pricing Dispute Cases

October 31, 2025 05:06 PM

OECD Reports Rise In Failed Advance Pricing Agreements

October 28, 2025 03:07 PM

UN Committee Seeks Feedback On Tax Treaty, Dispute Ideas