Transfer Pricing Report

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Tax Pros Uneasy as Canada Applies Draft Transfer Pricing Rules

The Canada Revenue Agency’s enforcement of a draft transfer pricing rewrite is leaving tax professionals wrestling with ambiguities, they say, as legislation for the revamp remains stalled.

Canada’s Proposal to Expand Tax Audit Powers Sparks Concerns

Expansion of Canada’s power to gather tax information, as the government is proposing, would open companies and individuals to excessive penalties, more government mistakes, and expensive disputes, tax professionals say.

India Ruling Reinforces Limits on Tax Agency’s Treaty Actions

Multinational businesses operating in India have new clarity on the tax authority’s limits in applying global rules meant to curb treaty abuse, after a court rejected the agency’s denial of tax benefits.

Zuckerberg Pressed Trump on Digital Taxes Before Tariff Vow

President Donald Trump threatened to inflict “substantial” tariffs on countries that impose digital taxes just days after Meta Platforms Inc. Chief Executive Officer Mark Zuckerberg raised concerns about the levies during a White House meeting.

Coca-Cola Cries Foul on IRS Tax Model in Transfer Pricing Tiff

The Coca-Cola Co. accused the IRS of trying to “game” the Tax Code and relying on errors from the US Tax Court to uphold a tax adjustment that could cost the company $12 billion.

PRACTITIONER INSIGHTS

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PepsiCo Australia Victory Highlights Need for Careful Contracts

Rezan Ökten

Dentons

India Hyatt Ruling Means MNEs Must Review Control Structures

Aditya Singh Chandel

AZB & Partners

PepsiCo Tax Win Shows Australia Can’t Wish Royalties Into Being

Shaun Cartoon

Arnold Bloch Leibler

Latest Stories

Acting IRS Large Business Unit Head Becomes Latest to Depart

The IRS division that audits the biggest multinational companies and wealthy individuals is losing another veteran leader.

By Erin Slowey and Erin Schilling

India Tax Cut to Make Life, Health Insurance Affordable for Many

A long-awaited tax exemption for health and life insurance could make the products cheaper by almost a fifth, boosting demand among millions of Indians without a cover.

US Weighs Tariffs If Global Ship Emissions Charges Are Approved

The US is considering imposing tariffs in response to an international proposal to charge ships for their carbon dioxide emissions to help fight climate change.

EU-Swiss Tax Information-Sharing Agreement Nears Approval

EU envoys agreed Wednesday on a draft that would update the current agreement between the EU and Switzerland on the exchange of financial information.

Medtronic IP Deal Assigned Transfer Pricing Standard on Appeal

Medtronic Inc.‘s intellectual property deal with its Puerto Rican subsidiary is best priced using the IRS’s proposed method for determining arm’s-length consideration, the Eighth Circuit said Wednesday.

Alvarez & Marsal Tax Names Five to Lead New Thailand Practice

Global professional services firm Alvarez & Marsal has launched Thailand operations with appointment of five practitioners to lead A&M Tax.

Trump’s New Child Tax Credit Deems Millions ‘Too Poor’ to Qualify

Columnist Andrew Leahey says state child tax credit programs should make credits targeted, refundable, and responsive to local needs, given the latest federal credit’s shortcomings.

Global South Faces Obstacles to Improving Tax Dispute Resolution

Developing nations’ efforts to improve their cross-border tax dispute resolution processes face ongoing hurdles and disincentives, officials and practitioners said at a Switzerland event.

Australia Mulls PepsiCo Decision’s Impact on Software Guidance

Australia’s tax office is considering how its loss at the High Court in a key royalty-tax case involving PepsiCo Inc. will affect its draft guidance on how software makers are taxed.

Nestle, Novartis Tax Heads Rue Global Minimum Tax Uncertainty

Tax heads at Nestle, Siemens and Novartis criticized the global minimum tax agreement at a conference Monday, lamenting its complexity and the lack of clarity around its future.