Transfer Pricing Report

IRS Refers Unanswered Transfer Pricing Nudge Letters for Audit

Corporate taxpayers getting letters from the IRS regarding their transfer pricing positions in the US have been mostly responsive, an IRS official said Thursday, but those that haven’t answered have been referred for audit.

Coca-Cola Appeals $2.6 Billion Transfer Pricing Tax Ruling

Coca-Cola Co. is appealing a US Tax Court decision on a transfer pricing dispute related to its Brazilian affiliate companies that could cost it $2.6 billion in taxes and billions more in interest.

Cut Admission Rules for Advance Tax Pacts, US Group Asks Brazil

Brazil should scrap its proposed limits on who can apply to a program meant to reduce uncertainty in a firm’s transfer pricing, a major US business group wrote.

Amgen’s $11 Billion Transfer Pricing Dispute Draws Investor Suit

An investor is suing Amgen Inc.'s leaders over the company’s $10.7 billion fight with the IRS, which has said the biopharmaceutical giant dodged a huge tax bill by shifting profits to a subsidiary.

3M, IRS Grilled Over Brazilian Law in Transfer Pricing Suit

Eighth Circuit judges focused on 3M Co.‘s level of control over its Brazilian subsidiary during oral arguments Tuesday about 3M’s tax liability, with one judge appearing particularly skeptical of the IRS’s justification for its tax increase.

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Austria Gazettes Tax Amendment Act 2024

The Austrian Official Gazette July 19 published Law No. 113, on the Tax Amendment Act 2024, which amends various tax laws. The law includes measures: 1) explaining that specified grants, ...

United Arab Emirates Tax Agency Explains Application of Related Parties Definition Under Corporate Tax Law

The Emirati Federal Tax Authority July 22 issued Public Clarification No. CTP002, explaining the application of the term, “related parties,” under the Corporate Tax Law, where there is a common ...

India Lower House Considers 2024 Finance (No. 2) Bill

The Indian lower house of Parliament (Lok Sabha) July 23 accepted for consideration Bill No. 55/2024, the 2024 Finance (No. 2) Bill. The bill includes measures to: 1) set progressive ...

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