Transfer Pricing Report

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Oracle’s Court Win Foils Australia’s Hope for Royalty Tax Ruling

Australia tax officials were frustrated this week in their desire for a domestic court decision on whether Oracle Australia’s transactions with an affiliate contained embedded royalties subject to withholding tax.

UN Tax Panel Looks to Expand Use of Advance Pricing Agreements

The United Nations group responsible for helping developing countries raise tax revenue decided Thursday to expand its work in transfer pricing by drafting guidance on the negotiation of unilateral advance pricing agreements.

UN Body to Tackle Tourism Transfer Pricing, Critical Minerals

The United Nations committee charged with helping developing countries raise tax revenue will develop guidance on transfer pricing, critical minerals, and the taxation of digital and service firms in the coming years.

Medtronic Seeks Panel Rehearing of Transfer Pricing Decision

Medtronic Inc. is asking a three-judge panel of the Eighth Circuit to rethink a recent transfer pricing decision siding with the IRS on how to value its transfer of intellectual property to a Puerto Rican subsidiary.

A view of Coca-Cola in New York City. (Photo by Tasos Katopodis/Getty Images for NYCWFF)

3M Case Marks Pathway for Coca-Cola’s Transfer Pricing Victory

Coca-Cola Co. has an opportunity to leverage a recent federal appeals court transfer pricing decision against the IRS in its own dispute over as much as $18 billion in taxes and interest tied to royalty payments to the beverage giant’s international affiliates.

Practitioner Insights

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Oracle Australia’s Victory Protects MAPs, Tax Treaty Obligations

Shaun Cartoon

Arnold Bloch Leibler

Gap in German Tax Law Hinders OECD Profit Allocation Approach

David Zarecky

Reptune Tax

IRS Settlement Indicates Continuation of M&A Carveout Fights

Saul Mezei

Gibson Dunn

Latest Stories

Argentina Gets Good Signs in Appeal of $16 Billion US Award

The government of Argentine President Javier Milei got reason to hope that its recent political and economic victories would continue in the legal arena when US appeals judges signaled openness to overturning a $16 billion court judgment against the South American nation.

By Jonathan Gilbert and Bob Van Voris

Australia Updates Advance Pricing Agreement Staff Instructions

The Australian Taxation Office issued updated instructions for its staff working on advance pricing agreements with companies hoping to get certainty for their tax positions.

India’s Faster Tax Agreement Processing Buoys Professionals

India’s advance tax agreements program has emerged as an effective option for multinationals to avoid protracted litigation.

Italy’s Flat Tax Is a Mounting Fiscal Gamble the US Has Mirrored

Italy’s recent move to raise its existing flat tax on future wealthy residents reveals the limits of its plan and is a cautionary tale for US tax policy: When governments prioritize short-term relief for the wealthy, they create structural deficits that must eventually be backfilled through temporary sources of revenue.

UN Proposes Public Transfer Pricing Database in Tax Treaty Talks

A United Nations committee is gauging support for including mechanisms for resolving transfer pricing disputes in a global tax treaty under negotiation.

Australia Seeks Input On Proposed Global Minimum Tax Tweaks

Australia is mulling changes to its global minimum tax regime and is seeking taxpayer input.

Volatile Policy Stalls US Aim to Lure Business Tax Refugees Back

At the beginning of his second term, President Donald Trump and congressional Republicans talked about giving US companies with a large overseas presence every reason to come back.

MNEs Face Transfer Pricing True-Up Challenges in Time of Tariffs

Tariffs may cause MNEs to need to make true-up adjustments to ensure transfer pricing compliance.

Week in Insights: Poland ‘Zero Tax for Families’ Is Good Branding

This week, experts examined IRS furloughs, health-care subsidies, and more.

French International Tax Audits Brought in €5.2 Billion

French tax authority auditors saw a spike in recovered unpaid taxes last year, led by adjustments on corporate transfer pricing positions and other international tax arrangements.