Transfer Pricing

Top News

Top International Tax Policy To Watch In 2026

By Kevin Pinner

The details of a proposed U.S. exemption from the global minimum tax's international provisions, possible retaliatory measures by the U.S. government and the rollout of major changes in Congress' latest budget are high priority for tax professionals going into 2026. Here, Law360 previews international tax practitioners' top priorities for the coming year.

Top International Tax Cases To Watch In 2026

By Natalie Olivo

Major multinational corporations such as McKesson and Coca-Cola will continue to litigate high-stakes international tax cases in 2026, including transfer pricing disputes with billions of dollars on the line and fights over whether regulations exceed the government's authority. Here, Law360 looks at four key international tax cases to follow in the new year.

Top International Tax Cases Of 2025

By Molly Moses

Government tax administrations came up short in some of the biggest international cases decided this year, including Denmark's challenge to a British trader it accused of deceiving the tax authority into paying thousands of improper refunds. Here, Law360 examines seven of the year's top international tax cases.

EU Looking To Merge Tax Directives Into Single Instrument

By Molly Moses

The European Commission is considering consolidating the nine bloc directives on administrative taxation cooperation — which cover such areas as the Organization for Economic Cooperation and Development's global minimum tax, crypto-asset reporting and cross-border tax rulings — into one legal instrument.

Treasury Issues Final Rule On BEAT For Securities Lending

By Kevin Pinner

Taxpayers must determine and account for certain qualified derivative payments linked to securities-lending transactions when calculating payments covered by the base erosion and anti-abuse tax, according to a final rule released Wednesday by the U.S. Department of the Treasury.

Developing Nations Expand Corporate Tax Breaks, OECD Says

By Kevin Pinner

Low- and middle-income countries generally expanded corporate tax incentives in 2024, while some coupled those measures with tax increases, the OECD reported Tuesday.


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.

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