The IRS’s defeat in a long-running dispute with pharmaceutical maker Perrigo Co. threatens to muddle the agency’s campaign to wield the controversial economic substance doctrine against taxpayers in transfer pricing audits.
Australian tax authorities are working on fewer advance pricing agreements than they used to, and negotiations are taking longer as cases are more complex.
Global profit shifting by public and multinational companies continues to be a source of major tax disputes for Australia’s tax office, it reported Friday.
On this week’s episode of Talking Tax, University of Kentucky professor Stephen Lusch talks with reporter Caleb Harshberger about how transfer pricing and tax law concepts can help show whether NIL deals are done at reasonable prices that really reflect the value the student brings.
Hello and welcome to the Transfer Pricing Report. I’m Caleb Harshberger, and this week we have news from Lisbon, where tax officials shared some of the latest tax and transfer pricing projects in the works at the OECD and around the world. Also, practitioners in Australia criticize the country’s newly finalized third-party debt test.
The European Parliament on Thursday voted to approve a call to simplify the EU’s tax code as part of the bloc’s drive to boost its economy and industry.
Tax pros say a new test meant to fix a clash between Australia’s tax rules and the realities of financing real estate and infrastructure development is too narrow and may hamper investment.
The Brazilian government intends to release guidance on unilateral advance pricing agreements before the end of the year, a tax official said Wednesday.
The OECD is revisiting its transfer pricing guidelines to identify rules that can be clarified and streamlined, an official for the organization said Wednesday.
It’s still not uncommon for a domestic builder or plumber to ask for payment in cash. Soon, they might ask for Tether or another stablecoin instead.
Apollo, Northwestern Mutual Future Ventures, Pantera Capital and Stillmark are joining Bain Capital and crypto investor Haun Ventures to back the Bitcoin life insurance firm Meanwhile in a $82 million funding round.
Tax professionals warned EU policymakers’ effort to integrate potential changes to the global minimum tax system into its existing law could threaten the bloc’s rule of law.
States that want to tax economic presence over contractual reality should codify the practice instead of implying it in court, and courts shouldn’t be tasked with stretching statutory language until it snaps.
The Liechtenstein Fiscal Authority Oct. 3 announced the Oct. 2 signing of a DTA with Latvia. The DTA includes measures to: 1) regulate the elimination of double taxation on cross-border ...
The Belgian Official Gazette Sept. 1 announced that the second protocol to the 1993 DTA with India, signed March 9, 2017, entered into force June 26, 2025. The provisions apply: ...
The Saudi General Authority of Zakat and Tax Oct. 1 announced that the DTA with Qatar, signed May 30, 2024, took effect Jan. 1, 2025, with its provisions being implemented ...
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