Transfer Pricing

By Anna Scott Farrell

The Sixth Circuit said Eaton Corp. doesn't have to comply with an IRS demand to produce performance reviews for its foreign employees until the appellate court decides whether to overturn a decision that the agency's transfer pricing investigation of the multinational power management company outweighed worker privacy concerns.

By Josh White

A London court backed HM Revenue & Customs in a case over more than £167 million ($212 million) in diverted profits tax charges issued to U.K. companies in the Thomson Reuters media group.

By Jack McLoone

The number of open dispute resolution cases under the OECD's mutual agreement procedure decreased nearly 4% in 2023, the first time the OECD observed an annual drop in such cases, it said Friday.

By Kevin Pinner

The European Union should strengthen its rules for combating tax avoidance by categorically including certain income of controlled foreign corporations and by limiting deductions for intragroup royalties and service fees, the Tax Justice Network said in response to a consultation by the bloc.

By Jack McLoone

The Internal Revenue Service plans to hold a public hearing Nov. 22 on proposed regulations that outline when foreign taxes under the Pillar Two international minimum tax agreement could trigger U.S. rules that aim to prevent companies from double-dipping the same economic loss.

By Jack McLoone

The Australian Taxation Office clarified that the country's new thin capitalization rules must be applied after both transfer pricing and debt deduction creation rules following amendments to the country's tax rules.