Transfer Pricing

By Molly Moses

Spain and the United States signed an agreement spelling out the process for binding arbitration under their tax treaty, which requires an independent panel to resolve disputes by selecting only one side's position, according to an IRS announcement Friday.

By Kevin Pinner

The European Union should require large companies to submit country-by-country tax reports to authorities when bidding for public contracts, a tax transparency group and EU public-sector union said ahead of the bloc revising its public procurement laws.

By Molly Moses

A former General Motors subsidiary in Portugal should not have its value-added tax increased after the Portuguese tax authority determined that its bearing the cost of repairing defects amounted to a service to manufacturers, an adviser to Europe's top court said Thursday.

By Molly Moses

Judges in several recent transfer pricing cases, including Facebook's, have reached their decisions by constructing their own valuation methods using elements of those put forth by both sides — an approach that, while it may lead to fair results, has economists questioning these hybrid methods' integrity.

By Josh White

The European Union's executive body is implementing changes to the 15% minimum corporate tax regime across the trade bloc after a renegotiation of Pillar Two last week, according to a notice published Monday.

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.