Transfer Pricing Report

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AI-Juiced Cross-Border Services Business Boom Raises Tax Issues

A wave of artificial intelligence tools is opening the door to new business opportunities and supercharging questions about how to tax service-based industries with clients that span the globe.

India Supreme Court Boosts Foreign Companies’ Tax Arguments

The Supreme Court of India is providing support for foreign companies fighting tax department claims that subsidiaries in the country constitute permanent establishments, with the tax liabilities they bring.

UK Backs Off Transfer Pricing Rules for Medium-Sized Companies

The UK government will drop its plan to bring medium-sized businesses under the country’s transfer pricing rules.

Treasury, IRS Withdraw Tax Return Preparer Oversight Proposal

The Treasury Department and IRS withdrew proposed rules regarding which tax return preparers are eligible to obtain a preparer tax identification number.

OECD Peers Advised 26 Countries to Improve Tax Ruling Exchanges

The OECD asked 26 countries to improve their facilitation of tax rulings that help tax authorities in risk assessments and counter base erosion and profit shifting concerns, according to a new report.

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UK Joins the ‘Median Club’ With Its Transfer Pricing Adjustments

David Zarecky

Reptune

OECD’s Tax Dispute Resolution Programs Are a Welcome First Step

Amanda Worcester Martin

Baker McKenzie

Economic Substance Doctrine, Penalty Lie in Wait for Taxpayers

Laura Gavioli

Proskauer

Latest Stories

Week in Insights: EU Climate Measure Is ‘Protectionist Parity’

This week, experts analyzed the Trump administration’s order on marijuana rescheduling, R&D tax credits, and more.

Colgate to Fight Nearly $30 million in India Tax Adjustments

Colgate-Palmolive’s India unit will appeal a $29.8 million tax adjustment from the Indian tax authorities—the latest in a string of tax disputes for the company in recent years.

Remote Work Boom Demands Tax Clarity: Transfer Pricing Report

Hello and welcome to the Transfer Pricing Report. I’m Caleb Harshberger, and this week we are taking a look at mounting concerns from businesses and tax practitioners about the tax treatment of remote workers, whose numbers have been on the rise since the 2020 Covid-19 pandemic.

Remote Work Boom Sparks Industry Call for Clearer Tax Rules

Tax professionals are calling for more consistency in global tax rules covering remote workers, saying the current patchwork of approaches across jurisdictions is causing big headaches for multinational companies.

IRS Voluntary Disclosure Update May Fail to Lure Rich Tax Cheats

Proposed changes to an IRS program meant to lure wealthy tax evaders to come clean with a promise of lower penalties intend to make it more popular, but taxpayers could still hesitate to self-report.

PwC Coaches New Tax Associates on AI Tools in US Training Effort

PwC’s new training program aims to give early-career recruits hands-on experience integrating artificial intelligence tools into everyday work.

The IRS Has a Chance to Fix Its Voluntary Disclosure Program

The IRS voluntary disclosure program has become so punitive and high-risk that it undermines its own purpose. With proposed reforms including a more structured penalty framework and streamlined processing finally on the table, the agency has a rare opportunity to turn it into a fair and functional path back into the system.