Transfer Pricing

By Kevin Pinner

The OECD's subject-to-tax rule would not affect any treaties between the organization's members and major developing countries, while the United Nations' alternative version could raise revenue more effectively, according to a report from the Group of 24 nations and an intergovernmental think tank. 

By Jack McLoone

The OECD updated 12 countries' entries in its transfer pricing database Tuesday, showing that while none of these countries has adopted the simplified approach for addressing baseline marketing and distribution activities known as Amount B, many have reached a political agreement on the measure.

By Anna Scott Farrell

Taxpayers can use an exception in the tax code for payments for services rendered by foreign related parties without applying a related U.S. Treasury Department regulation's provisions for transfer pricing purposes, the IRS Office of Chief Counsel said Friday.

By Josh White

The European Union looks set to collide with President Donald Trump's administration unless a trade deal can be secured soon, while the future of the global minimum tax rules looks far more doubtful than at the start of the year. Here, Law360 looks at current EU tax policy to determine what developments businesses should be watching over the next six months.

By Molly Moses

Canada's Department of Finance is considering changes to legislation that outlines the tax authority's power to recharacterize transactions set forth in contracts between related parties when their behavior doesn't match what the contract says, an official said Thursday.

By Kevin Pinner

The U.S. hasn't yet secured an agreement with other countries to exempt its companies from the international parts of the 15% global minimum tax despite reaching an "understanding" with the Group of 7 nations, but wider negotiations have begun, a U.S. Treasury Department official said Thursday.