ÃÛÌÒÊÓÆµ

Transfer Pricing

Top News

8th Circ. Urged To Enforce IRS Pricing Method On Medtronic

By Kevin Pinner

The U.S. Tax Court erred by tossing the IRS' suggested method to price royalties for intangible property licensed by medical device maker Medtronic to a Puerto Rican affiliate because its products differed from those of comparable uncontrolled companies, a government attorney told the Eighth Circuit on Tuesday.

Eaton Allowed To Shield Some Worker Reviews From IRS

By Anna Scott Farrell

Eaton Corp. may withhold performance evaluations for three foreign employees from the IRS' investigation of Eaton's sale of intellectual property to an Irish affiliate, an Ohio federal judge decided Monday, saying the records are not important enough to the tax investigation to justify violating European privacy law.

Co. Urges Ending IRS Cost-Sharing Rule After Justices' Ruling

By Anna Scott Farrell

A controversial rule requiring U.S. companies to include employee stock-based compensation in cost-sharing agreements with offshore affiliates should be scrapped following the U.S. Supreme Court's revocation of required judicial deference to agencies, a drug distributor told a Texas federal court in seeking a nearly $10 million tax refund.

Multinationals Grapple With Tariff-Induced Pricing Issues

By Dylan Moroses

President Donald Trump's flurry of tariff actions since taking office has created new questions for multinationals and their transfer pricing tax planners, including how to properly account for cost increases associated with new duties in related party transactions.

IRS Shouldn't Elect To Use OECD Pricing Method, AICPA Says

By Kevin Pinner

The IRS shouldn't unilaterally apply the Organization for Economic Cooperation and Development's streamlined approach to price-related companies' baseline distribution and marketing costs and should give companies a wide berth to choose the approach, the American Institute of Certified Public Accountants told the agency.

UK Seeks Input On Replacing Diverted Profits Tax

By Josh White

The U.K. government is holding a consultation on plans to replace the country's diverted profits tax by changing corporation tax and transfer pricing rules, HM Revenue & Customs said Monday.


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

April 23, 2025 02:36 PM

Eaton Allowed To Redact Employee Docs Before Court Review

April 9, 2025 05:48 PM

Eaton Asks To Redact Docs Before Court Review Of Tax Case

April 2, 2025 06:31 PM

6th Circ. Orders Private Review Of Docs In Eaton Tax Case

March 31, 2025 05:54 PM

India Sets New High Of APAs Signed In A Year

March 27, 2025 04:59 PM

Final APAs Dipped Slightly From 2023 Record High, IRS Says

March 27, 2025 06:45 PM

Pfizer Tops Pharma Tax Avoidance, Senate Dems Say

March 20, 2025 03:52 PM

PwC, Deloitte, KPMG Back Coke In $2.7B Dispute In 11th Circ.

March 19, 2025 06:09 PM

Technical, Policy Questions Still Swirl Around Amount B

March 19, 2025 03:36 PM

Switzerland, Zimbabwe Sign Tax Treaty

March 19, 2025 08:27 PM

Coke's $2.7B Tax Bill Arbitrary, Business Groups Tell 11th Circ.

March 18, 2025 05:27 PM

Microsoft Cost-Share Receipts Tax Fight Sent To Trial In Mich.

March 13, 2025 07:21 PM

Eaton Shouldn't Be Allowed To Shortcut Appeal, 6th Circ. Told

March 12, 2025 04:18 PM

Tariffs Prompt Chipmakers To Look At Manufacturing Moves

March 12, 2025 05:35 PM

Starbucks' Sourcing Aided $1.3B Low-Tax Profits, Report Says

March 7, 2025 05:56 PM

Mauritius Government Lawyer Joins CMS Affiliate

March 7, 2025 05:50 PM

NFTC Supports Broader, Elective Adoption Of Amount B

March 4, 2025 03:48 PM

IRS Asks To Toss Abbott Labs' FOIA Action For Tax Records

March 4, 2025 03:19 PM

'Guardrails' Needed In IRS Bid For Eaton Docs, 6th Circ. Told

February 27, 2025 03:50 PM

Progress Continues On Amount B, OECD Head Tells G20

February 26, 2025 02:12 PM

Coke's $2.7B Tax Bill Due To 'Bait And Switch,' 11th Circ. Told