Topic
Transfer Pricing
302 published works
Tax Controversy 360
Tax Court Hands Eaton a Complete Victory on the Cancellation of its Advance Pricing Agreements
On July 26, 2017, the United States Tax Court (Tax Court) handed a complete victory to Eaton Corporation (Eaton) relating to the Internal Revenue Service’s (IRS) cancellation of two Advance…
International Financial Law Prof Blog
Eaton Wins Important Transfer Pricing Case About IRS Post-Review of APAs
Eaton Corp. v. Commissioner, T.C. Memo. 2017-147 Eaton and the IRS entered into two advance pricing agreements (APAs) establishing a transfer pricing methodology for covered transactions between Eaton and its…
International Financial Law Prof Blog
OECD releases further guidance for tax administrations and MNE Groups on Country-by-Country reporting (BEPS Action 13)
The Inclusive Framework on BEPS has released additional guidance to give certainty to tax administrations and MNE Groups alike on the implementation of Country-by-Country (CbC) Reporting (BEPS Action 13). The additional guidance…
Israel Global Gateway
The Mutual Agreement Procedure: A Taxpayers’ Tool Reinvented
By Israel Group
Tax risks of multinational enterprises are expected to continue to increase post-BEPS (Base Erosion and Profit Shifting) as tax authorities globally increase their scrutiny on their cross-border tax transactions. This…
International Financial Law Prof Blog
Public comments published on the BEPS discussion draft on the Implementation Guidance on Hard-to-Value Intangibles
On 23 May 2017, interested parties were invited to provide comments on a discussion draft that provides guidance on the implementation of the approach to pricing transfers of hard-to-value intangibles described in…
International Financial Law Prof Blog
OECD releases the draft contents of the 2017 update to the OECD Model Tax Convention
The OECD Committee on Fiscal Affairs has just released the draft contents of the 2017 update to the OECD Model Tax Convention prepared by the Committee's Working Party 1. The update has not yet…
International Financial Law Prof Blog
OECD releases latest updates to the Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations
Today, the OECD releases the 2017 edition of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations. The OECD Transfer Pricing Guidelines provide guidance on the application of the “arm’s length…
International Financial Law Prof Blog
IRS Launches Transfer Pricing Country-by-Country Reporting Pages To Collect and Share U.S. Multinational Tax Information
The Internal Revenue Service launched Country-by-Country Reporting pages to share U.S. multinationals financial and tax information in a key performance/profilt level indicators XMS format with foreign countries in which the companies have a…
International Financial Law Prof Blog
The Platform for Collaboration on Tax delivers a toolkit to help developing countries address the lack of comparables for transfer pricing analyses and better understand mineral product pricing practices
The Platform for Collaboration on Tax (PCT) – a joint initiative of the International Monetary Fund (IMF), Organisation for Economic Co-operation and Development (OECD), United Nations (UN) and World Bank…
International Financial Law Prof Blog
OECD releases BEPS discussion drafts on transactional profit splits
Public comments are invited on the following discussion drafts: Revised Guidance on Profit Splits, which deals with work in relation to Actions 8-10 ("Assure that transfer pricing outcomes are in…