Transfer Pricing

Top News

IRS Properly Nixed Whistleblower's Award Bid, Tax Court Says

By Zak Kostro

The IRS didn't abuse its discretion in denying a whistleblower's bid for an award for information regarding alleged underpayments by a large multinational corporation, the U.S. Tax Court ruled Thursday, upholding the agency's determination that it had already identified the key issues for its investigation.

IRS Defends Regs In Meta's Fight Against $16B Tax Bill

By Natalie Olivo

The IRS urged the U.S. Tax Court to validate regulations that Facebook parent Meta is challenging in its fight against a nearly $16 billion tax bill, arguing that the social media giant is recycling arguments the Ninth Circuit already rejected.

Perrigo Shifted $212M In Profits To Shell Co., US Tells 6th Circ.

By Kevin Pinner

A Michigan court errantly allowed pharmaceutical giant Perrigo to avoid taxes on $212 million in profits by assigning a lucrative contract to a shell company that played no economic role in fulfilling its terms, the government told the Sixth Circuit.

Dutch Weigh Offering Source-State Service Taxes In Treaties

By Kevin Pinner

The Netherlands is looking at amending its policy on negotiating tax treaties so that it could offer all developing countries the ability to levy taxes on payments for all types of services even when the services aren't performed in the treaty partner's jurisdiction, according to a consultation.

S. Korea Probing $743M Tax Evasion By Biz In Food, Platforms

By Kevin Pinner

South Korea is investigating about 1 trillion won ($743 million) in suspected tax evasion by 41 companies primarily in the food sector as well as transfer pricing by online platform operators, the National Tax Service said Monday.

Ørsted Secures UK Tax Rights For 2 Offshore Wind Farms

By Josh White

An advisory commission issued an opinion saying Danish multinational Ørsted should pay taxes primarily in the U.K. rather than Denmark on two offshore wind farms based in British territory, according to a company statement.


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

September 8, 2026 04:23 PM

IRS Accepting Applications To 2027 Real-Time Audit Program

September 8, 2026 06:28 PM

Eaton Challenges IRS Example On Intercompany Loans

September 4, 2026 02:26 PM

Singapore's Tax Take Rises To $77B, Driven By Biz Tax

September 4, 2026 05:42 PM

Pfizer Can't Cut Ala. Tax With Shuffled Loans, Court Affirms

September 2, 2026 07:03 PM

Airbnb Can't Nix IRS Expert In $1.3B Bill Fight, Tax Court Says

September 1, 2026 01:30 PM

UN Tax Pact Should Avoid Gross Basis Taxes, Businesses Say

September 1, 2026 10:02 PM

Siemens Leaders Testify They Were Unaware Of Tax Strategy

August 31, 2026 09:26 PM

Siemens Urges Court Toward Wide View Of 2018 Restructuring

August 28, 2026 11:20 AM

Siemens To Defend Restructuring, $3.5B Deduction At Trial

August 25, 2026 01:37 PM

Romania Transfer Pricing Dispute Sent To Top EU Court

August 21, 2026 05:44 PM

Apple Paid $17B Taxes To Ireland In 2025, Mostly Due To ECJ

August 18, 2026 03:08 PM

HMRC Opens Registration For Tax Advisers

August 17, 2026 02:50 PM

Atlassian Seeks To Reup Australia Advance Pricing Agreement

August 17, 2026 03:15 PM

UnitedHealth Says IRS Seeking Transfer Pricing Adjustments

August 17, 2026 03:41 PM

McKesson's $10M Tax Refund Bid Misreads Law, Gov't Says

August 14, 2026 03:13 PM

UN Seeks Input On Draft Tax Convention And Protocols

August 14, 2026 06:48 PM

Meta's Litigation Distinct From Facebook's, IRS Says

August 13, 2026 04:58 PM

Africa Wants Precedence For UN Tax Pact's Dispute Protocol

August 11, 2026 05:41 PM

Nations Concerned By Nexus For Service Fees In UN Tax Pact

August 7, 2026 05:59 PM

Int'l Tax In July: New UK PM, Win For Denmark, US Tariff Pivot