Transfer Pricing

Top News

Upcoming IRS Regs Will Have Optional Amount B Pricing

By Natalie Olivo

The Internal Revenue Service announced Wednesday that is planning to propose regulations that will give corporations the option to price certain cross-border transactions using a simplified and streamlined approach under a new international tax framework known as Amount B.

Loper Bright May Influence Tax Less, IRS Chief Counsel Says

By Dylan Moroses

The U.S. Supreme Court decision this year overturning a decades-long standard to defer to federal agencies' regulatory interpretations has encouraged the Internal Revenue Service to better explain its rules, its outgoing chief counsel said Friday.

Mexico To Join Int'l Pricing Program In 2025, Official Says

By Molly Moses

Mexico plans in 2025 to join the International Compliance Assurance Program, a multilateral effort to resolve transfer pricing issues, an official from that country's tax authority said Thursday.

IRS Hopes To Issue Amount B Pricing Guidance Within Weeks

By Molly Moses

Treasury is working to finish its guidance on the simplified transfer pricing approach to baseline marketing and distribution known as Amount B by the end of the year, a U.S. official said Thursday.

OECD Removes Application Deadline For Int'l Pricing Program

By Dylan Moroses

The Organization for Economic Cooperation and Development said Thursday it has removed biannual deadlines for large multinational entities to apply for the International Compliance Assurance Program, a multilateral effort to resolve transfer pricing issues.

Australia Mulling More Country-By-Country Reporting Advice

By Jack McLoone

While the Australian Taxation Office is already working on guidance for the country's newly adopted public country-by-country reporting rules, it is looking for input on what other areas of the provision businesses may need assistance in interpreting.


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

December 5, 2024 04:10 PM

Dutch Gov't Will Not Adopt Amount B Pricing Framework

December 2, 2024 04:00 PM

Australia Passes Public Country-By-Country Reporting

November 27, 2024 04:50 PM

UN Approves Start Of Formal Talks On Global Tax Convention

November 18, 2024 04:07 PM

6th Circ. Pauses IRS Summons For Eaton Worker Docs

November 18, 2024 01:52 PM

HMRC's £167M Charges To Reuters Group Deemed Lawful

November 15, 2024 03:02 PM

OECD Dispute Resolution Caseload Drops For First Time

November 7, 2024 05:57 PM

EU's Anti-Tax Avoidance Rules Underperforming, Group Says

November 7, 2024 12:10 PM

IRS To Hold Hearing On Dual Consolidated Loss Regs

November 5, 2024 04:03 PM

Australia Clarifies Thin Capitalization Rules Interactions

November 1, 2024 05:37 PM

NOL Rules May Retain Favorable Approach, IRS Counsel Says

October 31, 2024 06:29 PM

Treasury Using Help To Clear Pillar 1 'Logjam,' Official Says

October 31, 2024 06:03 PM

Oracle Can't Pause $166M Royalty Cases In Australia

October 24, 2024 06:21 PM

IRS Forming Transfer Pricing Team To Aid Real-Time Audits

October 23, 2024 06:34 PM

Microsemi's Fines Mostly Adhered To Rules, Tax Court Says

October 22, 2024 07:09 PM

8th Circ. Judge Presses IRS On 3M Transfer Pricing Tax Ruling

October 21, 2024 06:30 PM

BDO Appoints Former HMRC Official, 3 Others To UK Offices

October 15, 2024 06:22 PM

Microsoft's Cost-Share Tax Arguments 'Deficient,' Mich. Says

October 11, 2024 05:59 PM

NJ Seeking Transfer Pricing Consultant For Audits, Litigation

October 10, 2024 05:16 PM

Pfizer Lone Holdout In Senate Pharma Tax Probe, Wyden Says

October 9, 2024 03:34 PM

3M Tax Ruling Must Fall Post-Chevron, Chamber Tells 8th Circ.