Transfer Pricing

Top News

3M Tells 8th Circ. IRS Used Invalid Regs For $24M Allocation

By Natalie Olivo

Multinational conglomerate 3M reiterated Friday its bid for the Eighth Circuit to reverse a U.S. Tax Court decision allowing the IRS to allocate nearly $24 million from the company's Brazilian affiliate, arguing the agency's adjustment relied on substantively invalid regulations.

Later Pillar 1 Due Date Set For June As Tax Talks Wrap Up

By Kevin Pinner

Diplomats agreed this week to finalize a treaty for reallocating some of large companies' tax payments and setting standards to simplify some transfer pricing in lower-income countries by June 30 after having missed a March deadline, according to a statement published Thursday by the OECD.

Colombian Court Affirms Fossil Fuel Tax Break Must Stay

By Kevin Pinner

The Constitutional Court of Colombia affirmed its decision to strike down a law denying fossil fuel companies the ability to offset corporate income tax liabilities with deductions for royalty payments despite a severe impact to public finances, the country's president said.

IRS Again Delaying Dividend Anti-Abuse Regs

By Jack McLoone

The Internal Revenue Service is again extending the transition period for rules that govern certain financial transactions that could avoid withholding on dividend payments to foreign taxpayers, it announced Wednesday.

Turkey Will Introduce 15% Global Minimum Tax, Minister Says

By Kevin Pinner

The Turkish government will introduce the 15% global minimum corporate tax and will not provide any incentives that would allow companies to pay a lower rate, the country's finance minister told its public broadcaster Monday.

Transfer Pricing Deal Needed For Pillar 1, OECD Official Says

By Natalie Olivo

It's crucial for countries to agree on transfer pricing policies under an international profit reallocation agreement known as Pillar One as they work toward their end-of-June deadline to sign a related multilateral treaty, an OECD official said Friday.


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

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

May 14, 2024 11:25 AM

Aussie Senate Faces Separation Of Promoter Penalty, Gas Tax

May 14, 2024 06:11 PM

Law Prof Comes To Treasury's Aid In 3M Transfer Pricing Fight

May 14, 2024 04:48 PM

Microsemi Calls IRS' Penalty Approval 'Woefully Inadequate'

May 11, 2024 04:13 PM

Gov't Urges 8th Circ. To Uphold 3M's $24M Pricing Adjustment

May 10, 2024 06:59 PM

5 Goals Gov'ts Have For The UN Tax Convention

May 8, 2024 02:31 PM

UN To Publish Draft Terms Of Reference For Tax Pact In June

May 7, 2024 06:00 PM

Industry Groups Suggest Changes To Aussie Reporting Rules

May 4, 2024 01:33 PM

IRS Seeks More Info On Purpose Test In Buyback Tax Regs

May 3, 2024 08:02 PM

US Resisting More Scoping On Amount B, Economist Says

May 3, 2024 05:35 PM

Africa Seeks Early UN Reform On Transfer Pricing, Exchanges

May 1, 2024 07:16 PM

Middle East, North African Gov'ts Back UN For Corp. Tax Talks

May 1, 2024 05:18 PM

UN Must Improve Corp. Tax Rules, Platforms, Some Gov'ts Say

April 29, 2024 02:22 PM

OECD-UN Initiative Lands Developing Countries $2.3B In Tax

April 26, 2024 06:47 PM

4 Goals For Gov'ts To Pursue In The UN Tax Convention

April 23, 2024 05:48 PM

Int'l Pricing Pact Guidance Is Coming Soon, IRS Official Says

April 19, 2024 01:52 PM

Questions Loom Over China's Pillar 2 Participation

April 19, 2024 03:08 PM

India Signs Record Amount Of Advance Pricing Agreements

April 19, 2024 06:49 PM

UN Should Eye Unitary Taxes, DSTs For Tax Pact, Report Says