Topic
Transfer Pricing
302 published works
International Financial Law Prof Blog
OECD releases BEPS discussion draft on the transfer pricing aspects of financial transactions
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…
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
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…
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
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…
Tax Controversy 360
McDermott Continues to Receive Top Rankings in Tax in Chambers USA 2018
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…
International Financial Law Prof Blog
Tax Inspectors Without Borders is seeking expert tax auditors for audit capacity around the world
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…
International Financial Law Prof Blog
OECD and Brazil launch project to examine differences in cross-border tax rules
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.…
Tax Controversy 360
Let’s Get Ready to Rumble – Coca Cola Concentrates on Trial Preparation
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)…
International Financial Law Prof Blog
Eight FTA members kick off multilateral tax risk assurance programme to provide early certainty for tax administrations and MNEs
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…
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…
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…