Transfer Pricing

Top News

OECD Mulling Tweaks To Arm's-Length Range Guidance

By Molly Moses

The Organization for Economic Cooperation and Development's guidance on the arm's-length range is an area ripe for simplification because the resources needed to calculate and make adjustments to the range are sometimes out of proportion with the amount in dispute, an official said Wednesday.

EU Law Doesn't Shield Eaton Records, US Tells 6th Circ.

By Kat Lucero

The European Union's privacy law does not protect Eaton Corp. from having to disclose employee evaluation records in a transfer pricing dispute with the Internal Revenue Service, the U.S. government told the Sixth Circuit on Monday.

IRS Didn't Mislead Coke In $2.7B Pricing Case, 11th Circ. Told

By Anna Scott Farrell

The IRS did not lure Coca-Cola to continue using a transfer pricing method only to suddenly declare it unlawful, as the beverage giant claims, the agency told the Eleventh Circuit on Monday in opposing the company's bid to reverse a ruling that added $2.7 billion to its tax bill.

Top International Tax Cases To Watch In 2nd Half Of 2025

By Natalie Olivo

Major multinational corporations such as 3M and Coca-Cola are expected to continue litigating high-stakes international tax cases in the second half of 2025, including disputes that could test the application of the U.S. Supreme Court's ruling that gutted judicial deference to agencies. Here, Law360 looks at seven key cases to follow the rest of the year.

OECD-UN Tax Initiative Has Helped Collect $2.4B, Report Says

By Jack McLoone

A joint initiative between the Organization for Economic Cooperation and Development and the United Nations to help developing countries boost tax revenues has helped collect $2.4 billion in its decade of existence, the initiative reported Wednesday.

Investor's Personal Loans Close Door On UK Biz Tax Relief

By Kevin Pinner

A banker who provided himself non-arm's-length personal loans through his company thereby disqualified from tax relief his £1.5 million ($2.1 million) investment of foreign income into the firm, making him liable for more than £675,000 in tax, the U.K. Upper Tribunal said.


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

July 1, 2025 05:22 PM

IRS Docs Bid Flouts Foreign Privacy Rules, 6th Circ. Told

June 30, 2025 12:19 PM

OECD Program Is Benefiting Developing Nations, Report Says

June 30, 2025 12:26 PM

OECD Charts Course For Coming Years' Work

June 25, 2025 02:34 PM

UAE Publishes Mutual Agreement Procedure Guidance

June 24, 2025 02:44 PM

Eaton Urges 6th Circ. To Shield Worker Reviews From IRS

June 24, 2025 05:45 PM

US Won't Stand In Way Of Domestic Min. Taxes, Official Says

June 23, 2025 08:00 PM

US Rules On Amount B 'May Take Some Time,' Official Says

June 23, 2025 06:31 PM

Talks Ongoing On EU Digital Tax, Italian Official Says

June 16, 2025 05:31 PM

Book Profits Much Higher Than Taxable Income, Paper Says

June 11, 2025 01:22 PM

37% Of Romania Cos. Fall Short On EU Reporting Standard

June 6, 2025 05:34 PM

Facebook Ruling Casts Uncertainty On Cost-Share Disputes

June 5, 2025 02:36 PM

US Biz Council Wants Treaty Talks With Switzerland, Taiwan

May 30, 2025 05:47 PM

Ohio Judge Slams Eaton For Ongoing IRS Disclosure Fight

May 29, 2025 05:27 PM

Australia Outlines Compliance For Thin Capitalization Test

May 28, 2025 05:30 PM

Mexico Collected $982M From Transfer Pricing Last Year

May 22, 2025 02:11 PM

Turkey, Azerbaijan Don't Allow Amount B, OECD Reports

May 13, 2025 04:21 PM

8th Circ. Urged To Enforce IRS Pricing Method On Medtronic

May 12, 2025 05:25 PM

Eaton Allowed To Shield Some Worker Reviews From IRS

May 5, 2025 03:36 PM

Co. Urges Ending IRS Cost-Sharing Rule After Justices' Ruling

May 1, 2025 06:39 PM

Multinationals Grapple With Tariff-Induced Pricing Issues