Transfer Pricing

Top News

India Exempts Old Foreign Investments From Avoidance Rule

By Kevin Pinner

Foreign investors in Indian securities will not be subject to tougher scrutiny for tax avoidance with respect to gains from transactions made prior to April 2017 as of Wednesday, the country's Ministry of Finance said.

Apple's Top Irish Branch Had $1.4B Minimum Tax Bill In 2025

By Kevin Pinner

Apple's top subsidiary in Ireland had a $1.4 billion top-up tax liability under the 15% global minimum tax during its 2025 fiscal year, part of a $12.1 billion tax bill, according to its annual financial statement.

India Signs Record Number Of Transfer Pricing Agreements

By Kevin Pinner

India signed a record number of advance pricing agreements, nearly 220, during its 2025-26 fiscal year, bringing the country's total number of concluded agreements above 1,000, according to its tax authority.

US Biz Group Asks EU To Limit Tax Abuse Rules' Application

By Kevin Pinner

The European Union's anti-tax abuse provisions should be limited to situations where avoidance is a genuine risk, and the 15% global minimum tax should take precedence over the tax avoidance directive when inconsistencies arise, a U.S. business lobbying group told the bloc.

US Takes $89M Perrigo Economic Substance Fight To 6th Circ.

By Natalie Olivo

The U.S. government is appealing a Michigan federal court's conclusion that Perrigo overpaid $89.2 million in taxes, which was based on a finding that the company's transactions with a foreign affiliate had economic substance rather than sole tax avoidance purposes.

Canada Gov't Gets Procedural Win In Transfer Pricing Dispute

By Natalie Olivo

The Tax Court of Canada rejected a roof and insulation company's challenge against the government's decision to deny deductions for royalty payments to a foreign affiliate, holding that it doesn't have jurisdiction to adjust the company's cross-border pricing.


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 20, 2026 01:01 PM

Paris Firm Adds Longtime Transfer Pricing Expert

March 19, 2026 06:26 PM

Meta Says IRS Defying Settled Facts In $16B Tax Fight

March 13, 2026 04:04 PM

IRS Seeks To Dismiss Meta's Claim On Interest, Penalty

March 12, 2026 04:19 PM

Microsoft, Michigan Settle Cost-Share Receipts Tax Fight

March 11, 2026 12:24 PM

Transfer Pricing Cases Collected £3.4B Last Year, HMRC Says

March 10, 2026 12:39 PM

Medtronic, IRS Pursuing Settlement In Transfer Pricing Case

March 10, 2026 06:05 PM

Hewlett Packard To Fight IRS Transfer Pricing Adjustments

March 4, 2026 05:54 PM

11th Circ. Shouldn't Apply 3M Ruling To Coke, Gov't Says

February 26, 2026 05:21 PM

Belgium Loses Dispute With EU Over Foreign Tax Deductions

February 24, 2026 07:24 PM

EU Trade Chief Urges Skeptical Lawmakers To Pass US Deal

February 23, 2026 05:46 PM

EU Lawmakers Delay Vote On US Trade Deal Amid Uncertainty

February 20, 2026 03:44 PM

Full 8th Circ. Won't Revisit 3M's Win Against IRS

February 18, 2026 04:21 PM

Glencore Says It Paid $1B To HMRC Over Tax Disputes

February 17, 2026 02:42 PM

EU Seeks Feedback For Bill To Streamline Corporate Tax Laws

February 13, 2026 05:18 PM

Gov'ts To Explore Transfer Pricing Database For UN Tax Pact

February 11, 2026 02:22 PM

Tax Advisers Urge EU To Scrap Disclosure Rules

February 5, 2026 04:13 PM

UN Talks Aim To Identify Gaps On Harmful Tax Practices

February 3, 2026 03:00 PM

Virgin Islands Co. Wants Experts Barred In $11.5M Pricing Row

February 2, 2026 01:15 PM

EU Loses €14B In Taxes Annually From US Cos., Report Says

February 2, 2026 02:14 PM

OECD Amends Tax Treaty Manual To Up Dispute Resolution