Internal Revenue Service sign with a traffic signal in the foreground indicating a red light. The IRS’ recent advice memorandum on periodic adjustments suggests that the agency may belatedly start ...
Most jurisdictions with meaningful cross-border trade require multinational groups to prepare formal transfer pricing ...
Transfer pricing remains a strategic focus for multinational corporations, intricately linked to their global tax strategies and compliance frameworks. As businesses expand across borders, the impact ...
In an order dated Oct. 26, the US tax court denied Coca-Cola’s plea for reconsideration of its 2020 transfer pricing decision that increased the company’s tax liability by nearly $9 billion. The case ...
Federico Vincenti and Carola Valente Della Rovere of Valente Associati GEB Partners/Crowe Valente illustrate the key phases and examine how multinational enterprises can manage intercompany pricing ...
The AICPA provided comments to the IRS on forthcoming proposed regulations that will include the Organisation for Economic Co-operation and Development’s (OECD’s) simplified and streamlined approach ...
When you hear the term "transfer pricing," you might think it is a difficult system handled only by international tax experts.However, when looking at the ERP systems of manufacturers and trading ...
August was an exciting month for those who follow U.S. transfer pricing litigation. Courts handed down opinions in the high-stakes, long-running Medtronic MDT Inc. v. Commissioner and Eaton v.
Eric Linge, Vrajesh Dutia, and Ewan Kemsley of Deloitte challenge the routine use of interquartile ranges in transfer pricing ...
Law360 (February 16, 2024, 5:05 PM EST) -- Medical device company Medtronic asked the Eighth Circuit on Friday to overturn a decision rejecting its pricing method for licensing intellectual property ...
In a letter submitted to the U.S. Department of the Treasury and the Internal Revenue Service (IRS), the American Institute of CPAs (AICPA) provided comments in response to Notice 2025-04. This notice ...
India–UAE transfer pricing guide covering related parties, arm’s-length pricing, methods, documentation, Form 3CEB, UAE rules ...
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