Transfer Pricing

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.

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.

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.

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.

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.

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.