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Topic

Transfer Pricing

302 published works

  1. International Financial Law Prof Blog

    OECD releases BEPS discussion draft on the transfer pricing aspects of financial transactions

    By William Byrnes

    Public comments are invited on a discussion draft on financial transactions, which deals with follow-up work in relation to Actions 8-10 ("Assure that transfer pricing outcomes are in line with value…

  2. International Financial Law Prof Blog

    OECD releases new guidance on the application of the approach to hard-to-value intangibles and the transactional profit split method under BEPS Actions 8-10

    By William Byrnes

    the OECD released two reports containing Guidance for Tax Administrations on the Application of the Approach to Hard-to-Value Intangibles, under BEPS Action 8; and Revised Guidance on the Application of the Transactional…

  3. International Financial Law Prof Blog

    OECD invites public comments on the scope of the future revision of Chapter IV (administrative approaches) and Chapter VII (intra-group services) of the Transfer Pricing Guidelines

    By William Byrnes

    The OECD is considering starting two new projects to revise the guidance in Chapter IV (administrative approaches) and Chapter VII (intra-group services) of the Transfer Pricing Guidelines. Public comments are invited…

  4. Tax Controversy 360

    McDermott Continues to Receive Top Rankings in Tax in Chambers USA 2018

    By Editorial Team

    Chambers USA released its 2018 edition of annual rankings of law firms and lawyers in various practice areas. We are honored that Chambers USA has recognized McDermott’s tax practice and…

  5. International Financial Law Prof Blog

    Tax Inspectors Without Borders is seeking expert tax auditors for audit capacity around the world

    By William Byrnes

    Tax Inspectors Without Borders (TIWB) is looking for qualified tax auditors who are fluent in Ukrainian and/or Russian to participate in upcoming audit assistance programmes. If you have five or…

  6. International Financial Law Prof Blog

    OECD and Brazil launch project to examine differences in cross-border tax rules

    By William Byrnes

    The OECD and Brazil launched a joint project to examine the similarities and gaps between the Brazilian and OECD approaches to valuing cross-border transactions between associated firms for tax purposes.…

  7. Tax Controversy 360

    Let’s Get Ready to Rumble – Coca Cola Concentrates on Trial Preparation

    By Robin L. Greenhouse

    The main attraction in the US Tax Court (Tax Court) is just a few weeks away. On March 5, 2018, The Coca-Cola Company (TCCC) and the Internal Revenue Service (IRS)…

  8. International Financial Law Prof Blog

    Eight FTA members kick off multilateral tax risk assurance programme to provide early certainty for tax administrations and MNEs

    By William Byrnes

    A pilot of a new FTA programme for the multilateral risk assessment of large MNE groups was launched at an event today in Washington DC. The International Compliance Assurance Programme (ICAP) is…

  9. Tax Controversy 360

    IRS Releases Several Transfer Pricing Directives

    By Andrew R. Roberson, Lowell D. Yoder

    The Internal Revenue Service (IRS) Large Business and International (LB&I) Division recently released several directives (LB&I Directives) geared toward transfer pricing. LB&I acknowledges that significant LB&I resources are devoted to…

  10. Louisiana Law Blog

    Louisiana Department of Revenue Issuing Arm’s Length Transfer Pricing Adjustments

    By Jaye Calhoun, William Kolarik, Phyllis Sims, Angela Adolph

    The Louisiana Department of Revenue (the “Department”) has joined the ranks of cash-strapped states looking to raise additional corporate tax revenue through scrutinizing transfer pricing and proposing adjustments.  In transfer…