Transfer Pricing

Top News

IRS Accepting Applications To 2027 Real-Time Audit Program

By Natalie Olivo

The Internal Revenue Service is accepting applications for its compliance assurance process real-time audit program for 2027, the agency announced Tuesday.

Eaton Challenges IRS Example On Intercompany Loans

By Kevin Pinner

The IRS is misusing a regulatory example that is unrelated to its argument that Eaton cannot pay foreign affiliates for support that a lender would assume exists in the agency's bid to reduce related-party interest rates and fees, the company told the U.S. Tax Court.

Singapore's Tax Take Rises To $77B, Driven By Biz Tax

By Kevin Pinner

Singapore collected 97.3 billion Singapore dollars ($76.8 billion) in tax revenue during its 2025-26 fiscal year, about 9.4% more than the previous cycle, driven by corporate income tax, the country's Inland Revenue Authority said Friday.

Pfizer Can't Cut Ala. Tax With Shuffled Loans, Court Affirms

By Kevin Pinner

Pfizer cannot reduce its Alabama corporate income tax liabilities by deducting $658 million in interest payments made to an Irish affiliate that shuffled them to Luxembourg affiliates as tax-free dividends, the Alabama Court of Civil Appeals said Friday, affirming a lower court's decision.

Airbnb Can't Nix IRS Expert In $1.3B Bill Fight, Tax Court Says

By Natalie Olivo

The U.S. Tax Court denied Airbnb's bid to strike IRS expert witness reports from discovery proceedings in the company's challenge against a $1.3 billion tax bill, ruling Wednesday that a procedural rule governing expert testimony applies only to trials.  

UN Tax Pact Should Avoid Gross Basis Taxes, Businesses Say

By Kevin Pinner

The United Nations' tax convention should avoid gross basis withholding taxes, which could weaken trade and competitiveness while raising costs throughout supply chains, the International Chamber of Commerce said in comments for a consultation.


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

September 1, 2026 10:02 PM

Siemens Leaders Testify They Were Unaware Of Tax Strategy

August 31, 2026 09:26 PM

Siemens Urges Court Toward Wide View Of 2018 Restructuring

August 28, 2026 11:20 AM

Siemens To Defend Restructuring, $3.5B Deduction At Trial

August 25, 2026 01:37 PM

Romania Transfer Pricing Dispute Sent To Top EU Court

August 21, 2026 05:44 PM

Apple Paid $17B Taxes To Ireland In 2025, Mostly Due To ECJ

August 18, 2026 03:08 PM

HMRC Opens Registration For Tax Advisers

August 17, 2026 02:50 PM

Atlassian Seeks To Reup Australia Advance Pricing Agreement

August 17, 2026 03:15 PM

UnitedHealth Says IRS Seeking Transfer Pricing Adjustments

August 17, 2026 03:41 PM

McKesson's $10M Tax Refund Bid Misreads Law, Gov't Says

August 14, 2026 03:13 PM

UN Seeks Input On Draft Tax Convention And Protocols

August 14, 2026 06:48 PM

Meta's Litigation Distinct From Facebook's, IRS Says

August 13, 2026 04:58 PM

Africa Wants Precedence For UN Tax Pact's Dispute Protocol

August 11, 2026 05:41 PM

Nations Concerned By Nexus For Service Fees In UN Tax Pact

August 7, 2026 05:59 PM

Int'l Tax In July: New UK PM, Win For Denmark, US Tariff Pivot

August 6, 2026 02:30 PM

Meta Can't Force Stipulation Of Facts In $16B Tax Court Fight

August 5, 2026 12:29 PM

OECD Biz Group Asks For Clearer Transfer Pricing Guidelines

August 4, 2026 03:25 PM

Tax Court OKs 3M's $5.2M Due After 8th Circ. Nixed IRS Rule

July 30, 2026 05:29 PM

OECD To Publish Comments On Services Draft In August

July 29, 2026 03:56 PM

CORRECTED: Tipster's Info Didn't Aid IRS Audit Of Co., DC Circ. Told

July 29, 2026 05:50 PM

Official Defends IRS' Argument On Intercompany Loans