Transfer Pricing

Top News

Biz Group Slams IRS' 'Implicit Support' Argument In Eaton

By Molly Moses

An international business group urged the U.S. Tax Court to reject IRS arguments that Eaton Corp. deserved a higher credit rating due to its foreign parent's "implicit support," saying the case could significantly affect its members' U.S. tax liabilities.

Int'l Tax In April: Progress On Tariff Refunds, New Tax Cuts

By Molly Moses

U.S. Customs and Border Protection continued to make progress in April on its system for paying back the tariffs that President Donald Trump imposed under the International Emergency Economic Powers Act. Meanwhile, several countries and one U.S. state cut fuel taxes in response to the U.S. and Israel's war with Iran. Here, Law360 looks at those and other international tax developments from the past month.

Korean Court Cancels $46.6M Of Netflix's Tax Bill, Report Says

By Kevin Pinner

Netflix on Tuesday secured the cancellation of 68.7 billion won ($46.6 million) in taxes imposed by the Korean government in a dispute over the characterization of payments to a Dutch subsidiary, in a partial victory at a Seoul court, according to a news report.

Meta Says Tax Court Has Jurisdiction Over Interest Claim

By Molly Moses

The U.S. Tax Court has jurisdiction over whether Meta is due a refund of interest for 2019 because the company claimed an overpayment for that year along with its challenge to deficiencies assessed in 2017, 2018 and 2019, the social media giant argued.

Australia Updates Pricing Guide For Inbound Distributors

By Natalie Olivo

The Australian Taxation Office updated its transfer pricing guidance for multinational corporations that distribute products to retailers in the country, including new clarifications about the scope of the pricing guidelines. 

IRS Says Meta Pricing Adjustments Not Barred By Prior Ruling

By Molly Moses

The U.S. Tax Court's opinion on the pricing of Meta predecessor Facebook's transferred intangible assets doesn't prevent the IRS from making periodic adjustments based on transactions occurring over the life of the company's cost-sharing arrangement with an Irish subsidiary, the agency argued.


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

April 16, 2026 02:16 PM

OECD To Address Double-Tax Policy Quirk, Official Says

April 15, 2026 04:12 PM

Eaton Says Tax Court Can't Disregard Transfer Of $14B Asset

April 8, 2026 03:21 PM

Jamaica Saw $7.7B In Transfer Pricing Reports, OECD Says

April 6, 2026 01:54 PM

Int'l Tax In March: Tariff Refunds Coming Amid New Disputes

April 1, 2026 01:45 PM

India Exempts Old Foreign Investments From Avoidance Rule

April 1, 2026 04:23 PM

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

April 1, 2026 02:35 PM

India Signs Record Number Of Transfer Pricing Agreements

March 31, 2026 12:27 PM

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

March 27, 2026 04:35 PM

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

March 27, 2026 05:37 PM

Canada Gov't Gets Procedural Win In Transfer Pricing Dispute

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