Transfer Pricing

By Kevin Pinner

Tax authorities began more than 2,500 mutual agreement procedure cases last year involving transfer pricing, a record number representing a 29% increase from the previous year, the Organization for Economic Cooperation and Development said Friday.

By Kevin Pinner

The number of advance pricing agreements that were rejected or closed without an accord rose 19% last year compared with the previous year, and slightly fewer agreements were granted overall, the Organization for Economic Cooperation and Developmen said Friday.

By Kevin Pinner

Leaders of the intergovernmental negotiating committee on the United Nations framework convention on international tax cooperation are seeking comments on a template for the treaty and ideas for a protocol on dispute resolution.

By Molly Moses

Multinational companies with U.S. distributors that typically bear fewer business risks and earn low profit margins may be able to mitigate the effect of U.S. tariffs on their business as a whole by having a foreign principal bear the tariff costs, an attorney said Wednesday.

By Kevin Pinner

The U.S. is a significant exception to a swath of countries, including China, Japan and the U.K., that lack domestic rules allowing companies to use a transfer pricing method for baseline marketing and distribution activities known as Amount B, the OECD reported Wednesday.

By Kevin Pinner

Australia released guidance Wednesday detailing when companies can forgo detailed top-up tax calculations for a jurisdiction under a safe harbor for the 15% global minimum tax that is based on country-by-country reporting.