The Italian Supreme Court’s recent acceptance of a subsidiary’s no-fee guarantee for a parent company’s loan highlights what some tax practitioners see as growing willingness by courts to accept purely economic reasons for not charging intragroup fees, at least in the area of corporate finance.
The Australian Tax Office needs additional tools to discourage transfer pricing by tech companies hoping to avoid paying for local news content, the country’s commercial television broadcasters say.
An IRS legal memo on the agency’s ability to adjust a company’s profits continues to come up in audits of companies’ transfer pricing, an IRS official said Wednesday.
The European Commission pushed Luxembourg and Malta to strengthen measures against aggressive tax planning, warning both countries they’re susceptible to companies shifting profits to low-tax jurisdictions.
The OECD launched a public consultation Monday focused on updating transfer pricing guidance to clarify existing principles and provide practical examples for identifying and pricing intragroup services.
Australia issued guidance Tuesday on what information companies must disclose in their new public country-by-country tax reports and how, as the deadline for the first filings draws near.
Critics of the state and local tax deduction cap should accept its constitutionality but push for changes such as eliminating the cap’s marriage penalty, smoothing its phaseout, and requiring the Treasury Department to rationalize the treatment of pass-through entity taxes, Andrew Leahey writes.
The IRS has the authority to impose a rule that led to a $9.6 million tax bill against
The OECD’s proposed changes to its transfer pricing guidelines might prompt governments to push further into companies’ business activities, tax professionals say.
Liberty Global is asking for the entire Tenth Circuit to rehear its $110 million tax refund appeal, arguing that a panel decision against the telecommunications company will cause broad confusion for taxpayers.
US importers and trading partners must be close to despair. Threats are made, deals are announced, but nothing is ever settled.
Latch.it, maker of popular locks for recreational vehicles, lost a patent case that closed off its most valuable sales channel after a decision from an unusual judge: Amazon.
Robust taxpayer protection policies, transparent AI governance, strong data integrity practices, and meaningful human oversight are essential to ensuring that digital transformation enhances rather than undermines fairness, KPMG practitioners, Christian Wiesener, Barbara Mbaebie, and Akaoma Osele, say.
This week, experts analyzed Pillar Two compliance, state tax credits for renewable energy projects, and more.
A House panel with jurisdiction over tax policy is preparing legislation that would grant cryptocurrency holders greater flexibility in reporting gains on investments, a potential boon for the digital asset industry.
The Organization for Economic Cooperation and Development (OECD) June 1 opened a consultation on proposed amendments to the transfer pricing guidelines for intra-group services. The proposals include measures to: 1) ...
The Bahraini National Bureau for Revenue June 7 posted online a guide, in English, on transfer pricing under the domestic minimum top-up tax (DMTT) law, aligned with OECD Pillar two ...
The Swedish Ministry of Finance June 3 announced the same date signing of a second protocol to the 1986 DTA with Ireland. The protocol introduces new minimum standards for tax ...
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