Transfer Pricing Report

Canada Top Court Rejects Appeals on Best Venues for Tax Disputes

Canada’s top court rejected two appeals Friday challenging which of its lower courts can hear taxpayers’ particular challenges over tax and transfer pricing disputes.

Australia Delays Property-Finance Guidance, Seeks Land-Tax Input

Australia delayed planned guidance on inbound related-party financing by private groups in the property and construction industry.

Australia Clarifies Limits of Cross-Border Tax Deductions

Australia has further clarified when it could deny companies cross-border tax payment deductions, with the rules likely to impact more US multinational company transactions amid a crackdown of how global outfits conduct their tax affairs.

FedEx, US, Ordered to Explain How Chevron’s Fall Alters Tax Case

FedEx Corp. and the government each need to assess how the recent overturning of the Chevron doctrine will affect their ongoing tax dispute.

OECD Reports Progress, But No Deal Yet on Global Tax Treaty

An agreement on a global tax treaty remains elusive, as negotiators continue to work on ironing out differences over several issues, including a framework to simplify intercompany transactions.

PRACTITIONER INSIGHTS

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Brazil’s OECD Transfer Pricing Move Challenges Small Businesses

Josdemar Beni

Grant Thornton

Taxing Cows a Pragmatic Step Toward Mitigating Climate Change

Andrew Leahey

Drexel University School of Law

Brazil’s New Transfer Pricing Rules Make Detailed Records a Must

Imke Gerdes

Baker McKenzie

Latest Stories

OECD Reports Global Corporate Tax Rates Still Stable at 21%

Corporate tax rates have stayed nearly the same since 2019, stopping a long-term decline over the last two decades, OECD reported Thursday.

By Danish Mehboob

Accounting Leader Calls for CPA Training to Evolve (Podcast)

Training for CPAs must evolve to focus on the skills and experiences necessary to meet future market demands, the leader of the largest US accounting industry group said.

Australian Accounting Industry Draws Call for Regulatory Ramp Up

Australia’s accounting industry needs more intense regulatory scrutiny, particularly the large firms providing audit and other consulting services, tax transparency advocates and professional bodies told the Treasury.

OECD Asks for Input on Global Minimum Tax Return Instructions

The OECD on Wednesday asked for feedback on its instruction guide for a form companies use to comply with the global minimum tax rules.

Transfer Pricing in Brazil: Timing is Everything

Now that Brazil has officially shifted to a TP system largely consistent with the OECD Guidelines, MNEs operating in Brazil should quickly work to analyze and carefully document their Brazil operations for TP purposes—and try to minimize year-end TP adjustments, say KPMG practitioners.

Ireland Warns Against Windfall Profits as Corporate Tax Pours In

Corporate tax revenues in Ireland have been higher than anticipated this year, but officials warned Tuesday that their volatility could mean a drop over the next six months.

EU Countries Want Flexibility in Unifying Transfer Pricing Laws

EU countries back a draft plan to harmonize their laws on intercompany transactions with those of the OECD, but disagree with the way it should be implemented.

South Carolina Defends $1.4 Million Tax Bill on Tractor Supply

Tractor Supply Co. and its affiliates are so highly interdependent that it was appropriate for South Carolina to require them to file combined tax returns, the state revenue department told an appeals court.

Week in Insights: A Fine Art Collection Can Cover One’s Tax Bill

This week, our experts covered the Supreme Court’s Loper Bright ruling, PepsiCo’s successful appeal on Australia’s royalty tax, and more. For a look at the latest commentary and analysis, check out our weekly roundup.