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.

PRACTITIONER INSIGHTS

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State Transfer Pricing Cases Show Importance of Documentation

Sowmya Varadharajan

Crowe

3M Transfer Pricing Case Shows Ripple Effect of Chevron’s Demise

Lauren Ann Ross

Covington

AI May Take Transfer Pricing Up a Notch but Carries Some Risk

Thomas Herr

KPMG

Latest Stories

Week in Insights: Casualty Loss Deductions Need Fairer Approach

This week, experts analyzed Loper Bright’s impact on the 3M transfer pricing dispute, factors to consider before suing the IRS over unpaid ERC claims, and more.

G20 Finance Heads Urge OECD to Wrap Up Global Tax Reform Talks

The Group of 20 leaned on members of the Organization for Economic Cooperation and Development to quickly wrap up negotiations on the global tax reform plan.

EU Countries Mull Longer Implementation Time for VAT Overhaul

EU countries will have a longer timeframe to implement aspects of a VAT bill that affects platforms like Airbnb and Uber.

IRS Refers Unanswered Transfer Pricing Nudge Letters for Audit

Corporate Tax Leaders Weigh AI’s Risk-Reward Calculus (Podcast)

Artificial intelligence is becoming a bigger part of tax practice and policy every day. The Big Four are spending billions of dollars on AI models, and even mid-tier accounting firms seem willing to at least tread into generative AI transformation, albeit slowly.

Mineral Resources’ Ellison Faces Probe From Australian Watchdog

Australia’s corporate watchdog is investigating Mineral Resources Ltd. and its tycoon founder, Chris Ellison, after he made undeclared payments that avoided tax.

Germany Finalizes December 2024 Withholding Formula

Germany’s withholding formula specifically for December 2024 was finalized Oct. 18 by the country’s finance ministry without any changes from its draft.

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.

Courts Worldwide Diverge in Applying the Principal Purpose Test

Although over 100 countries have signed the Multilateral Instrument, courts around the world have diverged in their application of the Principal Purpose Test, says Christos A. Theophilou of STI Taxand.

IRS Approved Tax Penalties Against California Semiconductor Firm

The IRS partially prevailed on Tuesday in proving that its agents followed procedures when seeking approval for penalties assessed against semiconductor provider Microsemi Corp.