Tariff Chaos Raises Audit Risks for Transfer Pricing

Transfer pricing is increasingly becoming a hot area for tax audits, raising risks for companies as they try to navigate an uncertain political and economic environment, recently exacerbated by ever-changing US tariff rates on major trading partners.

Pharma Industry Weighs Where to Hold Its IP Amid Tariff Turmoil

President Donald Trump’s tariff policies are prompting large pharmaceutical companies to promise investments in US manufacturing, but it might let them keep the crown jewels—their intellectual property—overseas.

Medtronic Ruling Bolsters IRS-Favored Transfer Pricing Method

The Eighth Circuit’s decision to send the Medtronic case back to the Tax Court brings more certainty for companies involved in intercompany transactions by squashing the court’s controversial method to resolve the dispute.

US Companies Push for More Relief in US-G7 Minimum Tax Deal

Large American companies are asking for any new deal struck at the OECD exempting them from parts of the global minimum tax to be made retroactive.

Australia’s New Form Lets Firms Ask to Revoke Debt Test Choice

Australia issued Tuesday a new form for companies looking to revoke their chosen method for determining the amount of claimable debt deductions on their income taxes.

Latest Stories

Hashing Out US-World Tensions on ‘Side-by-Side’ Global Tax Deal

In this episode of Talking Tax, Bloomberg Tax reporters Saim Saeed and Lauren Vella hash out countries’ frustrations over global minimum tax exemptions and discuss the feasibility of coming to an agreement on a “side-by-side” system by Dec. 31, the deadline suggested by the Trump administration.

Tax Developments

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Brazil Gazettes Decree Promulgating Second Protocol to 2018 DTA With Singapore

The Brazilian Official Gazette Sept. 22 published Legislative Decree No. 203, promulgating the second protocol to the 2018 DTA with Singapore, signed April 17, 2023. The decree enters into force ...

Czech Republic MOF Updates List of DTAs

The Czech Ministry of Finance Sept. 19 posted an updated list of DTAs that have entered into force. The list is current as of the same date. [Czech Republic, Ministry ...

Spain Supreme Court Clarifies Transfer Pricing Rules for MNE Group Cash Pooling Arrangements

The Spanish Supreme Court July 15 issued Decision No. 985/2025, clarifying the transfer pricing treatment of cash pooling arrangements operated by multinational enterprise (MNE) groups. The taxpayer, the Spanish subsidiary ...

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