Transfer Pricing

Top News

BlueCrest Loses UK Top Court Fight Over LLP Tax Rule

By Josh White

Portfolio managers at hedge fund BlueCrest Capital Management LLP should be taxed as employees rather than partners under the U.K.'s salaried member rules, the U.K.'s top court ruled Wednesday.

Top International Tax Cases Of 2026: Midyear Report

By Molly Moses

The U.S. government came out ahead in four of the most closely watched international tax cases decided in the first half of 2026, scoring a victory against telecommunications giant Liberty Global and prevailing in a computational dispute over Varian Medical Systems, among others. Here, Law360 looks at some of the most significant court rulings from the year's first half.

Microsoft's Irish Tax Rate About 12%, Company Reports

By Kevin Pinner

Microsoft paid an income tax rate of about 11.9% in Ireland on a cash basis last year, compared to about 15.5% on an unweighted average in European Union countries where it booked a profit, according to the company's first public country-by-country tax disclosure.

Int'l Tax In June: Tariff Refunds Challenged, EU Sets Agenda

By Molly Moses

As U.S. Customs and Border Protection entered the second phase of its process for refunding invalidated tariffs in June, President Donald Trump's administration challenged its authority to issue those refunds. Here, Law360 examines some of the past month's biggest international tax developments.

Tax Court Tosses Meta's Interest Claim In $16B Dispute

By Kevin Pinner

The U.S. Tax Court said it has no jurisdiction to hear Meta's challenge to the IRS assessing interest on the company until it has decided whether a deficiency or overpayment exists in the company's underlying case over a $15.9 billion tax bill, according to an order.

11th Circ. Judges Question Coke's View Of IRS As Arbitrary

By Molly Moses

Judges for the Eleventh Circuit probed attorneys for Coca-Cola and the government Thursday about whether the IRS was arbitrary in abandoning its position in a closing agreement the beverage company had relied on for decades to calculate its transfer prices with related foreign suppliers.


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

June 23, 2026 05:29 PM

Trump Picks Miller & Chevalier Attorney For IRS Chief Counsel

June 22, 2026 03:35 PM

Swiss Seek Feedback On Tax Reporting Simplifications

June 18, 2026 03:34 PM

Indian Court Sides With US Gem Co. In Transfer Pricing Row

June 18, 2026 04:54 PM

Medtronic Ruling Supports IRS In Amgen Case, Tax Court Told

June 18, 2026 06:21 PM

Securitization Cos. Can Duck EU Interest Limits, Adviser Says

June 18, 2026 05:35 PM

Meta Says IRS Seeks 'Do-Over' Of Facebook Case

June 16, 2026 01:13 PM

UK Seeks Input On New Transfer Pricing Reporting Rules

June 12, 2026 02:28 PM

Ride App Bolt Can't Cut £190M VAT Bill After All, Court Rules

June 10, 2026 04:45 PM

Amgen Can't Amend Petition To Address Potential Double Tax

June 10, 2026 05:34 PM

Irish Aim To Refine EU Tax Transparency As Council President

June 8, 2026 02:56 PM

McKesson Can't Defeat Valid Cost-Sharing Rules, Gov't Says

June 5, 2026 05:12 PM

Abbott Says Timing Mismatch Lets $8B Gain Go Untaxed

June 1, 2026 03:53 PM

OECD Seeks Input On Revision To Transfer Pricing Guidelines

June 1, 2026 07:54 PM

Int'l Tax In May: Tariff Refunds Begin, New Levies Thrown Out

May 27, 2026 12:51 PM

Amazon's UK Tax Bill Topped £1.3B In 2025

May 26, 2026 03:41 PM

African Tax Forum Helped Raise $686M In 2025, Report Says

May 22, 2026 07:26 PM

Meta Says IRS Must Stipulate To Court Findings In Facebook

May 21, 2026 12:26 PM

UK To Crack Down On Energy Giants' Offshore Tax Planning

May 21, 2026 05:13 PM

Amgen Wants To Preserve Right To Seek Double Tax Relief

May 21, 2026 01:14 PM

EU Elects New Chair Of Int'l Tax Conduct Group