Companies need additional guidance on the impacts of remote work on corporate taxes and the creation of taxable permanent establishments, practitioners told the OECD in comments as part of the group’s global workforce mobility project.
SentinelOne resolved its transfer pricing dispute with the Israeli Tax Authority this month regarding certain intercompany transactions between the company and its Israeli subsidiary, the company said in financial filings Wednesday.
Multinational groups should conduct rigorous value chain analysis for their UK entities to accurately reflect financial transactions and ensure compliance with transfer pricing rules, the UK tax authority said Thursday.
The Australian Taxation Office is working on new guidance to crack down on related-party property development arrangements that it believes are being used to improperly defer paying taxes on project profits, potentially indefinitely.
The OECD plans to issue a raft of global minimum tax guidance clarifying the treatment of certain businesses and accounting standards, an official said Thursday.
Hello and welcome to the Transfer Pricing Report. I’m Caleb Harshberger, and this week we’re checking out the growing mountain of TP cases facing the IRS this year, even amid all the budget cuts and staffing departures at the agency over the last year. And we’re following up on the EU advisory opinion on Stellantis’ case involving TP adjustments and VAT.
A European Court of Justice adviser’s opinion involving the automaker Stellantis adds to a growing body of legal guidance on how value-added tax applies to pricing adjustments between related companies.
In this episode of Talking Tax, Christian Kaeser, global head of tax at Siemens AG, told Bloomberg Tax reporter Ryan Hogg that some of his European counterparts regarded the deal as “lopsided” but welcomed new permanent safe harbors that were created with input from Business at OECD, known as BIAC. Kaeser is co-chair of BIAC’s tax committee.
Pharma giant AstraZeneca plans to fight a $1.3 million tax and transfer pricing adjustment in India, after the company’s subsidiary received an order from tax authorities late last week.
If the federal government is abandoning partnership enforcement, states—especially high-income states—have every reason to step in, as a pool of trained, experienced partnership auditors are suddenly available.
This week, experts examined the US’ Pillar Two side-by-side deal, state and local tax issues to watch in 2026, and more.
Taxpayers increasingly are taking alternative avenues to resolve their tax disputes with the IRS, with a 28% boost in cases in 2025, an official said Friday.
Hello and welcome to the Transfer Pricing Report. I’m Caleb Harshberger, and this week we’re looking at the mountain of comments the OECD got about global workforce mobility and permanent establishments. Surprise, surprise! Folks want/need more guidance. Plus, an advocate general opinion in the EU’s top court on Stellantis’ TP adjustments and VAT, and more.
India’s Income Tax Act, 2025, introduces a new era of digital enforcement and enhanced administrative powers and fundamentally reshapes certain long-standing tax principles.
The Danish Customs and Tax Administration Jan. 20 posted online City Court Decision No. SKM2026.40.BR, clarifying permanent establishment (PE) rules for nonresident contractors under the 2001 Denmark-Poland DTA. The taxpayer, ...
The Armenian Ministry of Finance Jan. 21 posted a synthesized text, in English, of the 2001 DTA and protocol with Estonia, and the Multilateral Convention to Implement Tax Treaty Related ...
The Armenia Ministry of Finance Jan. 21 posted a synthesized text, in English, of the 2009 DTA and protocol with Croatia, and the Multilateral Convention to Implement Tax Treaty Related ...
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