Transfer Pricing

Top News

India Eyes End Of Digital Tax For E-Commerce, But Not Ads

By Kevin Pinner

Foreign e-commerce companies would be exempted from India's equalization levy, a 2% digital tax, but online advertisers would continue to pay a 6% rate on gross revenues sourced to Indian customers under a budget bill presented Tuesday by the government.

Newell Says IRS Misapplied Pricing Law In $124M Dispute

By David Hansen

Newell Brands told the U.S. Tax Court the Internal Revenue Service misapplied transfer pricing law to levy almost $124 million in additional taxes and penalties.

UN Aims Tax Convention At Digital Economy, Rich Individuals

By Kevin Pinner

The United Nations General Assembly should take aim at taxation of the digital economy and wealthy individuals in a framework convention on international tax cooperation, according to a U.N. committee's revised draft term of reference released after a consultation.

US Treasury Working To Extend Pillar 1 DST Compromise

By Dylan Moroses

As OECD-led negotiations continue on a taxing rights overhaul known as Pillar One after a missed June deadline, the U.S. Treasury Department is working to extend the political agreement between it and several countries to nullify their digital services taxes once the rights overhaul is implemented.

International Tax Policy To Watch In The 2nd Half Of 2024

By Kevin Pinner

An abundance of loose threads pervades the international tax landscape as the first year of the global minimum tax unfolds, with the battle over digital services taxes still smoldering and diplomats talking tougher taxes on the wealthy. Here, Law360 looks at international tax policy to watch in the second half of 2024.

Tax Pros Say Gov'ts Stretching 'Realistic Alternative' Analysis

By Molly Moses

Tax authorities including the Internal Revenue Service are overstepping in their use of "realistic alternative" arguments, substituting their own judgment for that of businesses, transfer pricing specialists said Thursday.


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 18, 2024 12:22 PM

Top International Tax Cases To Watch In The 2nd Half Of 2024

July 18, 2024 03:40 PM

Most Top US Cos. To Report Tax Under Aussie Bill, Study Says

July 18, 2024 07:04 PM

Treasury Starting To Address Amount B, Official Says

July 17, 2024 05:31 PM

Aussie Gov't Seeks Tighter Promoter Penalties After PwC Leak

July 17, 2024 03:03 PM

IRS Plans August Hearing On Stock Buyback Tax Rules

July 17, 2024 05:59 PM

Gov't Views On OECD Risk Guidance Vary, Economists Say

July 16, 2024 07:33 PM

More Geographic Adjustments 'On The Table' For Amount B

July 16, 2024 08:58 PM

Intracompany Prices Should Reflect Acquired IP, Panelists Say

July 16, 2024 05:08 PM

EU Opposed Fast-Tracking Reforms Under UN Tax Convention

July 12, 2024 08:54 PM

Chevron's End Doesn't Bear On 3M's Case, IRS Tells 8th Circ.

July 11, 2024 02:48 PM

Tax Haven Biz Revenues Per Worker Still Far Outpace Norm

July 5, 2024 04:04 PM

Tractor Supply Incorrectly Shifted Income, SC Tells Court

July 5, 2024 11:08 AM

Top Federal Tax Cases To Watch In The 2nd Half Of 2024

July 2, 2024 04:57 PM

Eaton Needs To Cough Up Docs In IRS Probe, US Says

July 1, 2024 02:19 PM

OECD Tax Chief Affirms Pillar 1 Progress As Deadline Passes

June 28, 2024 01:21 PM

EU Leaders Nominate President Von Der Leyen For 2nd Term

June 27, 2024 06:23 PM

Aussie Betting Site Can't Duck Taxes Tied To News Corp. Sale

June 27, 2024 06:21 PM

High Response To IRS Transfer Pricing Letters, Official Says

June 25, 2024 11:57 AM

New EU Chair Hungary Eyes Talks On Corp. Tax, But No Deals

June 24, 2024 12:07 PM

EU States Turn Down Transfer Pricing Proposal, Report Says