Transfer Pricing

Top News

Accendra Pays $19M To Settle IRS Transfer Pricing Matter

By Natalie Olivo

Accendra Health Inc. paid $19 million to the Internal Revenue Service to conclude tax matters related to international transfer pricing activity between 2015 and 2018, according to a recent earnings call with investors.

GM Unit's Pricing Shift Doesn't Affect VAT, EU High Court Says

By Natalie Olivo

The Portuguese government should not have increased the value-added tax bill for automaker Stellantis, the European Union's top court ruled Wednesday, holding that intercompany transactions between the former General Motors Co. subsidiary and European manufacturers fell outside the VAT's scope.  

Meta Must Share Option Costs Post-Altera, IRS Says

By Molly Moses

The Ninth Circuit's 2019 ruling against Altera Corp., which upheld rules requiring companies to share the cost of employee stock options with foreign affiliates, means that Meta's income for 2017-18 should be increased by roughly $3 billion, the IRS told the U.S. Tax Court.

Amgen Late To Raise Double-Taxation Claim, Tax Court Told

By Kat Lucero

Biotechnology giant Amgen is making a "futile" attempt to raise a purported double-taxation issue for tax years 2016 through 2018 in a pair of transfer pricing cases before the U.S. Tax Court, the federal government said, arguing the disputed years fall outside the court's jurisdiction.

McKesson Says Loper Bright Sinks IRS Cost-Sharing Rules

By Natalie Olivo

Pharmaceutical giant McKesson asked a Texas federal court to strike down cost-sharing transfer pricing regulations that underpin the company's $10 million tax refund bid, arguing the U.S. Supreme Court's Loper Bright ruling forecloses previous deference to rule writers.

Admin Cost Of Tax Presence Shouldn't Top Profit, Pros Say

By Molly Moses

The administrative costs for a company or individual triggering a taxable presence, or permanent establishment, in a jurisdiction shouldn't exceed the profit allocable to the entity, transfer pricing specialists said Friday.


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

May 8, 2026 09:50 PM

AI's Use In Transfer Pricing Still Evolving, Tax Pros Say

May 4, 2026 03:37 PM

IRS Approves Co.'s Retroactive Transfer Pricing Changes

May 1, 2026 06:31 PM

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

May 1, 2026 06:09 PM

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

April 28, 2026 03:44 PM

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

April 28, 2026 05:53 PM

Meta Says Tax Court Has Jurisdiction Over Interest Claim

April 23, 2026 12:52 PM

Australia Updates Pricing Guide For Inbound Distributors

April 21, 2026 05:38 PM

IRS Says Meta Pricing Adjustments Not Barred By Prior Ruling

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