Transfer Pricing

Top News

Eaton Shouldn't Be Allowed To Shortcut Appeal, 6th Circ. Told

By Anna Scott Farrell

The Sixth Circuit shouldn't grant Eaton Corp.'s request to curtail arguments in its appeal of a court order enforcing an Internal Revenue Service summons for its European employee records, the federal government argued Thursday, saying it wants the chance to explain why foreign law doesn't apply.

Tariffs Prompt Chipmakers To Look At Manufacturing Moves

By Kevin Pinner

The U.S. semiconductor industry is considering moving manufacturing operations to the U.S. and elsewhere as a tariff-mitigation strategy with President Donald Trump threatening to levy the sector and its supply chains, professionals told Law360.

Starbucks' Sourcing Aided $1.3B Low-Tax Profits, Report Says

By Kevin Pinner

Starbucks leveraged its private certification program for coffee growers to boost profits transferred almost tax-free from Switzerland to the Netherlands to the U.K., amounting to an estimated $1.3 billion between 2011 and 2021, according to a report from a union-funded nonprofit organization.

Mauritius Government Lawyer Joins CMS Affiliate

By David Hansen

CMS said an attorney with more than a decade of experience as a Mauritius government lawyer has joined CMS Prism, the firm's Mauritian affiliate.

NFTC Supports Broader, Elective Adoption Of Amount B

By Jack McLoone

The U.S.' proposed adoption of the OECD's approach to pricing certain cross-border transactions, known as Amount B, should go beyond just marketing and distribution activities, the National Foreign Trade Council said Friday, suggesting it be extended to services and other baseline activities.

'Guardrails' Needed In IRS Bid For Eaton Docs, 6th Circ. Told

By Natalie Olivo

The IRS is seeking Eaton employee records that would violate European Union data protection laws, the power management multinational told the Sixth Circuit, arguing that an Ohio district court should accordingly only privately review the documents with "critical guardrails."  


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

March 4, 2025 03:48 PM

IRS Asks To Toss Abbott Labs' FOIA Action For Tax Records

February 27, 2025 03:50 PM

Progress Continues On Amount B, OECD Head Tells G20

February 26, 2025 02:12 PM

Coke's $2.7B Tax Bill Due To 'Bait And Switch,' 11th Circ. Told

February 24, 2025 02:10 PM

OECD Issues Consolidated Guidance On Amount B

February 14, 2025 05:56 PM

Alvarez & Marsal Appoints Tax Leader For Southeast Asia

February 5, 2025 02:33 PM

Denmark Floats Edits To OECD Tax Standards Adoption

February 4, 2025 04:24 PM

US Drops Out Early From UN Global Tax Convention Talks

February 3, 2025 03:57 PM

Indian Budget Would Simplify Transfer Pricing, Cut $11.5B

February 3, 2025 06:17 PM

UN Tax Pact Should Aim For Unitary Taxation, Economists Say

January 28, 2025 05:52 PM

OECD Details Documents Needed For Int'l Pricing Program

January 27, 2025 02:13 PM

Transfer Pricing Brought In £1.8B In Tax Last Year, HMRC Says

January 24, 2025 04:31 PM

Former Head Of MTC, Tenn. DOR Reflects On Years In SALT

January 24, 2025 12:38 PM

Australian Tax Transparency Rules Could Set Benchmark

January 17, 2025 06:58 PM

US Guidance On Amount B Carries Potential For Disputes

January 15, 2025 05:50 PM

Australia Gives Guidance On Foreign-Funded Construction

January 13, 2025 03:14 PM

Still No Unanimous Path Forward On Amount B, OECD Says

January 9, 2025 02:17 PM

Sri Lanka Publishes Advance Pricing Agreement Guidance

January 1, 2025 08:01 AM

Top Federal Tax Cases To Watch In 2025

January 1, 2025 08:01 AM

Top International Tax Cases To Watch In 2025

December 18, 2024 03:19 PM

Upcoming IRS Regs Will Have Optional Amount B Pricing