Trump’s About-Face in Law Firm Fights Casts Pall Over ABA Suit
Justice Department lawyers are heading to court today to defend President Donald Trump’s attacks on law firms after the administration backtracked on a move to drop out of those fights.
Transfer Pricing Report
Companies Aiming to Bring IP to the US Have a Pillar Two Problem
Companies are clamoring to bring their valuable intellectual property back to the US, as expanded tax benefits and the new side-by-side global tax system make repatriating suddenly more attractive, tax professionals said Wednesday. But there’s a problem.
Tech Heats Up Companies’ Transfer Pricing Transparency Risks
Tax agencies’ high-tech auditing tools are supercharging their enforcement efforts and corporate taxpayer headaches thanks to a pile-on of transfer pricing reporting requirements around the world.
Transfer Pricing Rules Apply in Poland Deferred-Tax Cases
A company opting for Poland’s deferred corporate income tax regime remains fully subject to transfer pricing rules, the Polish Supreme Administrative Court ruled.
OECD Helping Countries Adopt ‘Amount B’ Transfer Pricing Method
The OECD is working with a number of countries to implement a simplified transfer pricing method broadly agreed to in 2021—even as questions continue to swirl about which, if any, countries beyond the US and Singapore will actually adopt it.
3M Pays $18.8 Million After Reaching India Transfer Pricing Pact
A 3M Co. unit in India has recorded a tax expense of 170.95 crore ($18.8 million) after finalizing an advance pricing agreement to resolve transfer pricing-related tax litigation.
Practitioner Insights
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Aditya Singh Chandel
AZB & Partners
Jon Morton
Forvis Mazars
Jared Dunkin
FTI Consulting Inc.
Latest Stories
Trump’s IRS Lawsuit Offers Lessons on Privacy and Legal Process
President Donald Trump’s $10 billion lawsuit against the IRS should reinforce several lessons that extend well beyond this case: Taxpayer privacy is fundamental. Courts have tools to preserve fairness when structural conflicts arise. Presidential proximity to litigation decisions can heighten those conflicts. And policy choices about investment, access, and oversight have real-world consequences.
California SALT Deduction Proposal Is More Clever Than Helpful
A proposal to reclassify California’s vehicle sales tax as a licensing fee would do little to change its “donor state” status and benefit only a small group of wealthy Californians.
Week in Insights: EU’s VAT Fraud Bill Raises Questions of Power
This week, experts analyzed the OECD’s and UN’s international tax reform efforts, tax consequences of employee compensation clawbacks, and more.
OECD Appoints New Head of Info Exchange, Transparency Forum
Maria José Garde from Spain has been appointed the new Head of Secretariat of the Global Forum on Transparency and Exchange of Information for Tax Purposes at the OECD, the organization said Friday.
Argentina’s $40 Billion Copper Boom Hinges on Glacier Law Revamp
The way Argentina’s president and some of the world’s biggest miners see it, all that stands between them and billions in copper riches are hunks of icy rock and overzealous legislation.
Moving IP to US Encounters a Problem: Transfer Pricing Report
Hello and welcome to the Transfer Pricing Report. I’m Caleb Harshberger, and this week I swung by PLI to hear the latest on companies’ recent efforts to shift IP back to the US and why you’d rather have the IRS looking into your tax positions than the Italians. Plus, Pepsi loses in Illinois. And tariff refunds — if they materialize — will pose tough transfer pricing questions for companies.
How Does Tax and Business Alignment Drive Procurement Value?
Global disruption, rising costs, and digital innovation are transforming procurement into a critical driver of enterprise value—explore how a tax-informed operating model is reshaping the future of procurement.
Brazil Goes From Big Loser to Winner on US Tariffs: Supply Lines
Brazil turned the other cheek when Donald Trump slapped 50% tariffs on its goods last year, refusing to retaliate even as it faced some of the most painful levies in the US president’s arsenal.
Companies Aiming to Bring IP to the US Have a Pillar Two Problem
Companies are clamoring to bring their valuable intellectual property back to the US, as expanded tax benefits and the new side-by-side global tax system make repatriating suddenly more attractive, tax professionals said Wednesday. But there’s a problem.
Tax Developments
View MoreDenmark Tax Agency Clarifies Taxation of Indirect Loan Between Two Companies Under Common Control
The Danish Customs and Tax Administration Feb. 27 posted City Court Decision No. SKM2026.106.BR, clarifying the taxation of an indirect loan between two companies under common control. The taxpayer, an ...
Georgia Gazettes Order Introducing New Annual Requirements, Amendments to International Controlled Transactions Reporting Framework
The Georgian Official Gazette Feb. 25 published Order No. 52, amending the tax administration rules regarding international controlled transactions reporting. The order includes measures: 1) introducing mandatory additional reporting schedules ...
Kyrgyzstan, Romania Initial DTA
The Kyrgyzstan Ministry of Economy and Commerce Feb. 27 announced the Feb. 26 initialing of a DTA with Romania. [Kyrgyzstan, Ministry of Economy and Commerce, 02/27/26]
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