Transfer Pricing Report

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Canadian Firms Advised to Expand Transfer Pricing Analysis

Tax pros in Canada are advising clients to expand the scope and depth of their transfer pricing analyses in anticipation of tougher audits from the country’s tax authority.

Tax Pros Wonder About Outlook as IRS Pricing Agreements Slow

The diminished number of advance pricing agreements the IRS completed last year has tax practitioners wondering what the agency will do to get more APAs done with fewer resources.

Interest Deduction Tweak Prompts Thoughts of Offshore Borrowing

American companies with a big global footprint are reconsidering their debt strategies in the US after a change in Republicans’ 2025 tax law that limits their ability to deduct interest expenses.

Tax Dodgers Leave Kenya’s Revenue Agency With $7.6 Billion Gap

Less than half of Kenya’s registered tax payers are settling their obligations, resulting in a collection gap of at least 982 billion shillings ($7.6 billion), according to the nation’s revenue agency.

OECD Helps Jamaica Raise Nearly $8 Billion From Transfer Pricing

The OECD helped Jamaica train more than 70 tax officials on transfer pricing, leading to transaction disclosures worth €6.6 billion ($7.7 billion) from multinational companies, the body said in a report Wednesday.

Practitioner Insights

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Five Questions With Crowe Tax Principal Rochelle Hodes

Rochelle Hodes

Crowe

AI-Powered Transfer Pricing Enforcement Should Rouse MNEs to Act

Tulika Lall

BDO Switzerland

Five Questions With Stinson Tax Partner Harry Teichman

Harry Teichman

Stinson

Latest Stories

OECD Working on ‘Integrity Measures’ for Global Tax Deal

The OECD is working on guidance this year that would aim to prevent companies from abusing new global minimum tax rules, a top official said.

By Ryan Hogg

Critical to Preserve Tax Multilateralism, OECD Official Urges

The next five years are crucial in preserving progress on multilateralism, a top OECD official said as she laid out the case for further global tax cooperation after January’s landmark minimum-tax deal.

PwC Australia Profit Drops, But Fewer Partners Split the Pot

PWC Australia’s annual profit and revenue fell last year as it moved to incorporate AI into its auditing services.

Adapting to global fragmentation: Transfer Pricing Report

Hello and welcome to the Transfer Pricing Report. I’m Caleb Harshberger, and this week we’re taking a broad view, looking at how tax and transfer pricing heads are thinking about a more fragmented and decentraized world. Also, Luxembourg posts Amount B guidelines, an Indian court slaps down tax authority arguments for taxing fees for virtually provided services, and the OECD is investigating specifics for possible MAP guidance expansion.

Countries More Interested in Digital Tax Talks, OECD Official Says

Countries are leaning toward further engagement in digital tax talks, a top OECD official said Friday.

Don’t Let Your IP Transfer Pricing Catch You Off Guard

As fast-growing companies expand across borders, failing to align IP ownership with where value is created can trigger significant tax and deal risks.

Bombay Ruling Dampens India Effort to Tax Cross-Border Services

A recent Indian court order offers new support for multinational companies that say providing cross-border services remotely doesn’t make them liable for India corporate tax.

Corporate Tax Departments Face New Era of Global Fragmentation

The sudden reversal of the trend toward globalization has tax departments mulling how to adapt to a more fractured and decentralized world.

Luxembourg Details Approach to Simplified Transfer Pricing Rules

Luxembourg’s tax administration published guidelines Thursday for a streamlined approach to marketing and distribution activities under the OECD’s simplified transfer pricing rules.