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Tax Ruling for Netflix India Boosts View for Digital Sector

Netflix’s win in an India tax dispute signals that some international digital businesses may get friendlier treatment in the country than tax authorities would like.

Canada Sets Up Big Changes for Company Affiliate-Pricing Rules

Canadian tax professionals see a future with more tax disputes and probably higher tax bills under rules the government proposed this week strengthening its power to decide if a company’s affiliate transaction pricing is out of line.

Top Czech Court Confirms Hitachi Subsidiary’s Tax Adjustment

A top Czech Republic court upheld a 71.39 million Czech koruna ($3.43 million) tax loss reduction for a subsidiary of Hitachi Ltd. due to lack of compensation for a production line conversion.

Court Denies Medtronic Bid to Rethink Transfer Pricing Case

A three-judge panel at the Eighth Circuit denied Medtronic Inc.'s request to reconsider a recent decision in its transfer pricing dispute with the IRS over how it allocated income to a subsidiary in Puerto Rico.

UN Panel Meets in Nairobi to Chart Scope of Global Tax Treaty

The United Nations begins meetings in Nairobi on Monday to approve draft language spelling out the reach of a global tax treaty.

Practitioner Insights

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Multinationals in Argentina Must Navigate Investment Incentives

Augusto Mancinelli

DLA Piper

UN’s Public Transfer Pricing Database Faces Serious Roadblocks

Chad Martin

Eide Bailly

Oracle Australia’s Victory Protects MAPs, Tax Treaty Obligations

Shaun Cartoon

Arnold Bloch Leibler

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Hungary Passes Global Minimum Tax Updates, Reporting Rules

The Hungarian parliament passed two bills Tuesday implementing wide-ranging tax changes and information reporting standards.

By Jan Stojaspal

Australia Delays Country-by-Country Reporting Due Date

Australia is giving taxpayers an extra month to file their country-by-country reporting statements “due to the year-end holiday period.”

Ireland’s Donohoe to Exit Government, Eurogroup for World Bank

Paschal Donohoe is set to step down as Ireland’s finance minister to become the managing director at the World Bank.

OpenAI’s Tax Subsidy Efforts Amount to Silicon Valley Socialism

OpenAI’s push to expand the CHIPS Act tax credit into a broad artificial intelligence infrastructure subsidy shows how the government, and by extension taxpayers, are already underwriting the AI boom—just as the industry’s massive energy and land use burdens begin hitting state and local budgets.

Nations Urge UN Panel Not to Touch Existing Tax Dispute Forums

Countries voiced strong support Monday for the United Nations to take an unobtrusive approach in crafting a new agreement on tax dispute prevention and resolution.

Australia to Update Transfer Pricing Guide for Imported Goods

Australia is working on updating its guidance on transfer pricing risks for companies importing foreign products and digital services.

How Will Generative AI Affect Value Chains and Transfer Pricing?

As GenAI continues to evolve, companies should monitor potential changes in their business models and value chains to understand the impact on existing transfer pricing structures and policies.

EU Proposes Sharing Value-Added Tax Data With Anti-Fraud Bodies

The European Commission on Friday proposed to allow EU countries to share value-added tax information with the bloc’s anti-fraud agencies.

Estonia Seeks More Time, More Agency on Global Minimum Tax

The Estonian government called for more decision-making power over whether to impose the 15% global minimum tax.

Netflix India Win Boosts Digital Sector: Transfer Pricing Report

Hello and welcome to the Transfer Pricing Report. I’m Caleb Harshberger, and this week we’re looking at Netflix’s recent court win in India that practitioners said could be a big boost for companies in the digital products and services industries.