Transfer Pricing

Top News

Sens. Press KPMG On Role In Microsoft's $29B Tax Play

By David van den Berg

Three senators pressed KPMG's CEO on allegations the company helped Microsoft skirt nearly $29 billion in taxes by illegally allocating profits to a Puerto Rico subsidiary and demanded additional information on KPMG's role in the arrangement.

OECD Touts Work Fighting Tax Dodging In West Africa

By Jack McLoone

The OECD and 16 West African nations have collaborated on three so-called community tax instruments to help the region fight base erosion and profit shifting in hope of improving their local economies, according to a report released Wednesday.

Alternative Apportionment Issues Linger After Justices' Punt

By Paul Williams

The U.S. Supreme Court's declining to hear an energy company's claims that Michigan unconstitutionally taxed gain generated from the sale of an out-of-state business highlights open questions about when alternative apportionment should be used to tax income from multistate entities.

EU Won't Speak For All On Transfer Pricing, Official Says

By Todd Buell

The European Union doesn't intend to speak for member countries in international discussions about transfer pricing standards, a European Commission official said Wednesday, discussing a new draft law.

Int'l Pricing Program Is Viable, IRS Official Says

By Kevin Pinner

Results presented Tuesday on a multilateral program to resolve transfer pricing issues show it is a viable option for companies, especially as a first step toward tax certainty, an IRS transfer pricing official said.

IRS Probing Partnership Tax Reporting Issues, Official Says

By Dylan Moroses

The Internal Revenue Service is sending letters to large U.S. partnerships, flagging possible tax reporting issues amounting to millions of dollars, the commissioner of the agency's Large Business and International division said Wednesday.

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.


November 8, 2023 06:39 PM

Coke Stuck With $882M Adjustment For Brazilian IP Transfers

November 8, 2023 07:09 PM

Transfer Pricing Rules Can Simplify Process, EU Advisers Say

November 8, 2023 07:30 PM

ConocoPhillips Owes $390M In Transfer Pricing Row, La. Says

November 7, 2023 04:54 PM

Over 200 Groups Call For UN Global Tax Treaty By Mid-2025

November 6, 2023 05:19 PM

OECD Seeks Comments On Transfer Pricing For Lithium

November 1, 2023 06:02 PM

Japan, Greece Sign Their 1st Double-Tax Treaty

October 30, 2023 05:53 PM

US Treasury Official Says DST Pause Should Continue

October 30, 2023 06:19 PM

Argentina Has Digital Withholding Tax Ready, Official Says

October 26, 2023 03:45 PM

OECD Details Withholding Tax Treatment In Profits Plan

October 25, 2023 04:23 PM

US Review Of OECD Multilateral Treaty May Impede Effort

October 24, 2023 08:48 PM

States Should Consider Bilateral Pricing Programs, Atty Says

October 20, 2023 02:14 PM

US, Chile Working To Finalize Tax Treaty, Official Says

October 20, 2023 02:02 PM

3 Lingering Issues Under New Int'l Transfer Pricing Plan

October 19, 2023 05:46 PM

India's High Court Restricts Some OECD Tax Treaty Perks

October 19, 2023 06:31 PM

Ireland's Proposed Min. Tax To Have Extra Safe Harbor

October 18, 2023 06:09 PM

China Signs Tax Treaties With Cameroon, Senegal

October 18, 2023 05:32 PM

Sen. Warren Presses Microsoft On $29B IRS Tax Bill

October 18, 2023 06:15 PM

Australia Seeks Comments On Limits To Debt Deductions

October 16, 2023 03:13 PM

OECD's Profit Plan Won't Be Ready Until 2024, Yellen Says

October 11, 2023 05:02 AM

OECD Reveals Multilateral Treaty For Profit Reallocation Plan