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Transfer Pricing
European Union
Ropes & Gray LLP
In this Ropes & Gray podcast, Ellen Gilley, an associate in the tax controversy group, is joined by Kat Gregor, a partner in the tax group and co-founder of the tax controversy group,...
The Organisation for Economic Co-operation and Development (OECD) has pushed for additional levels of transparency in the context of the Base Erosion and Profit Shifting ("BEPS")* project.
Duff and Phelps
On September 24, 2019, the General Court of the European Union released its decisions on two major State Aid cases.
United States
Ropes & Gray LLP
Microsoft Ruling Highlights Need To Document Biz Decisions.
On January 31, 2020, the OECD/G20 Inclusive Framework on BEPS released an update on its efforts to effect major changes in international tax rules.
Москва, 3 февраля 2020 года — Лидия Чарикова присоединилась к российской налоговой и там
Ruchelman PLLC
This month finds the arm's length principle continuing to operate among O.E.C.D. Member States and the broader inclusive framework working toward international tax reform of the digitized economy.
Duff and Phelps
The tax rate will double to 10% for the years 2019 through 2025, with a further increase to 12.5% after 2025.
Duff and Phelps
The additional tax payable under the BEAT calculation can be significant.
Duff and Phelps
In October 2015, the Organization for Economic Cooperation and Development (OECD) finalized its report titled Action 14: Making Dispute Resolution Mechanisms More Effective.
Duff and Phelps
The proposals under consideration would create a significant change to the current tax system for certain multinational companies.
Rimon P.C.
Incoming European Commission President Ursula van der Leyen has set out as her primary goal moving forward the mission of further unifying Europe and "protecting the European way of life."
Morrison & Foerster LLP
Last month a unanimous Ninth Circuit affirmed the Tax Court thereby preserving Amazon's victory in a major transfer pricing dispute
Ropes & Gray LLP
On August 16, 2019, the Ninth Circuit upheld Amazon's cost-sharing arrangement and valuation of its intangible assets, affirming the Tax Court's 2017 decision
Dickinson Wright PLLC
With the 9th Circuit Court of Appeal's recent decision in Inc. et al v Commissioner of Internal Revenue, upholding a U.S. Tax Court ruling rejecting a broader definition of intangible assets.
Cooley LLP
On August 9, the US Department of the Treasury released proposed regulations on the federal income tax treatment of "cloud transactions"
Mayer Brown
Prior to the Tax Cuts and Jobs Act of 2017 ("TCJA"), the appeal of cost sharing was driven largely by the deferral of U.S. taxation on foreign earnings.
Hogan Lovells
Driven by ever-advancing technologies, today's multinationals need to quickly adapt to new ways of doing business — a process that can often leave them more vulnerable to risk including tax and transfer pricing, ...
Duff and Phelps
In this edition of Transfer Pricing Times, we present the latest and most relevant transfer pricing issues and developments from around the globe.
Duff and Phelps
In this edition of Transfer Pricing Times, we present the latest and most relevant transfer pricing issues and developments from around the globe.
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