Transfer Pricing

Top News

OECD Biz Group Asks For Clearer Transfer Pricing Guidelines

By Eleanor Butler

A business advisory group to the Organization for Economic Cooperation and Development has asked for clearer transfer pricing guidelines from the group to determine how intragroup payments should be priced and documented, in a letter made public Wednesday.

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

By Natalie Olivo

The U.S. Tax Court signed off Tuesday on 3M Co. and the IRS' conclusion that the company overpaid its taxes by about $5.2 million, which the parties calculated after the Eighth Circuit rejected the agency's allocation of overseas income.

OECD To Publish Comments On Services Draft In August

By Molly Moses

The OECD plans to publish at the end of August the comments it received on draft revisions to transfer pricing guidelines dealing with intragroup services, an official said at a conference Thursday.

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

By Kat Lucero

The Internal Revenue Service appropriately denied a whistleblower award to an individual alleging that a company underpaid taxes by not following transfer pricing regulations, the U.S. government told the D.C. Circuit, saying the information did not contribute to an audit of the company.

Official Defends IRS' Argument On Intercompany Loans

By Molly Moses

Companies borrowing from their affiliates need to establish that they are doing so on an arm's-length basis, an Internal Revenue Service official said Wednesday, defending the agency's position in current litigation against Eaton Corp. at a conference in Washington, D.C.

UK Gov't Insists No Change For Businesses On US Tariffs

By Josh White

The U.K. government said Friday that there is no change in tariffs following the U.S. administration's decision this week to impose widespread duties after the expiration of a temporary global duty regime, as the trade deal allowing 10% tariffs between the two countries still holds.


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 23, 2026 12:56 PM

Biz Group Urges OECD To Clarify Transfer Pricing Updates

July 21, 2026 05:23 PM

Amgen To Pay $74M To End Investor Suit Over $10.7B Tax Bill

July 17, 2026 06:59 PM

Keysight Invalidates IRS Rule On GILTI, Abbott Says

July 16, 2026 06:51 PM

Meta Says Altera Ruling Doesn't Control In Stock Option Fight

July 15, 2026 08:46 PM

Eaton Says IRS Position Turns 'Arm's Length' On Its Head

July 15, 2026 04:22 PM

HMRC Still Weighing How To Treat Offshore Interest Income

July 13, 2026 04:41 PM

McKesson Says IRS Overreads Law Backing Pricing Rules

July 13, 2026 03:17 PM

UK Gov't To Implement Side-By-Side Tax Rules

July 2, 2026 11:34 AM

Top International Tax Cases To Watch In 2nd Half Of 2026

July 1, 2026 01:37 PM

BlueCrest Loses UK Top Court Fight Over LLP Tax Rule

July 1, 2026 12:12 PM

Top International Tax Cases Of 2026: Midyear Report

July 1, 2026 03:54 PM

Microsoft's Irish Tax Rate About 12%, Company Reports

June 30, 2026 07:14 PM

Int'l Tax In June: Tariff Refunds Challenged, EU Sets Agenda

June 26, 2026 03:32 PM

Tax Court Tosses Meta's Interest Claim In $16B Dispute

June 25, 2026 07:18 PM

11th Circ. Judges Question Coke's View Of IRS As Arbitrary

June 23, 2026 05:29 PM

Trump Picks Miller & Chevalier Attorney For IRS Chief Counsel

June 22, 2026 03:35 PM

Swiss Seek Feedback On Tax Reporting Simplifications

June 18, 2026 03:34 PM

Indian Court Sides With US Gem Co. In Transfer Pricing Row

June 18, 2026 04:54 PM

Medtronic Ruling Supports IRS In Amgen Case, Tax Court Told

June 18, 2026 06:21 PM

Securitization Cos. Can Duck EU Interest Limits, Adviser Says