Transfer Pricing

Top News

Eaton Asks To Redact Docs Before Court Review Of Tax Case

By Jack McLoone

Multinational power company Eaton Corp. asked an Ohio district court to allow it to redact information related to employees' sexual orientation and religious beliefs before the court's Sixth Circuit-ordered review of their records, saying such information isn't relevant to its transfer pricing dispute.

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

By Anna Scott Farrell

The Sixth Circuit granted a request by multinational power company Eaton Corp. to order a lower court to review in chambers sensitive performance evaluations in its transfer pricing case challenging an Internal Revenue Service summons for its European employee records.

India Sets New High Of APAs Signed In A Year

By Jack McLoone

India's Central Board of Direct Taxes blew past its previous record of advance pricing agreements signed in a single fiscal year, completing 174 agreements in 2024-25 compared with the last high mark of 125 a year prior, it said Monday.

Final APAs Dipped Slightly From 2023 Record High, IRS Says

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.

Pfizer Tops Pharma Tax Avoidance, Senate Dems Say

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.

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

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.  


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

March 19, 2025 03:36 PM

Switzerland, Zimbabwe Sign Tax Treaty

March 19, 2025 06:09 PM

Technical, Policy Questions Still Swirl Around Amount B

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

February 24, 2025 02:10 PM

OECD Issues Consolidated Guidance On Amount B

February 14, 2025 05:56 PM

Alvarez & Marsal Appoints Tax Leader For Southeast Asia

February 5, 2025 02:33 PM

Denmark Floats Edits To OECD Tax Standards Adoption

February 4, 2025 04:24 PM

US Drops Out Early From UN Global Tax Convention Talks

February 3, 2025 03:57 PM

Indian Budget Would Simplify Transfer Pricing, Cut $11.5B

February 3, 2025 06:17 PM

UN Tax Pact Should Aim For Unitary Taxation, Economists Say

January 28, 2025 05:52 PM

OECD Details Documents Needed For Int'l Pricing Program