Transfer pricing refers to the pricing of goods, services and intellectual property transferred between related entities within a multinational corporation. Companies use transfer pricing to allocate ...
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 ...
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 ...
This article explores transfer pricing disputes with tax authorities and related disclosures in financial statements. Recent increases in companies’ risk exposure from these controversies have raised ...
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 ...
The ITAT Mumbai held that transfer pricing adjustments for intra-group services were unsustainable because the TPO determined the arms length price without applying any prescribed method under Section ...
Tax Notes contributing editor Ryan Finley discusses the latest updates in recent transfer pricing cases Eaton and Medtronic II. This transcript has been edited for length and clarity. David D. Stewart ...
The Tribunal held that transfer pricing adjustments must be based on international transactions and not entity-level figures. It remanded the matter after finding errors in the computation of the ...
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