Transfer Pricing Report

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Tax Pros Wonder About Outlook as IRS Pricing Agreements Slow

The diminished number of advance pricing agreements the IRS completed last year has tax practitioners wondering what the agency will do to get more APAs done with fewer resources.

Interest Deduction Tweak Prompts Thoughts of Offshore Borrowing

American companies with a big global footprint are reconsidering their debt strategies in the US after a change in Republicans’ 2025 tax law that limits their ability to deduct interest expenses.

UK Transfer Pricing Data Push to Drive HMRC Queries, Revenue

Multinationals in the UK are bracing for a wave of targeted inquiries projected to increase transfer pricing revenue after the advent of a new documentation requirement.

India Tax Office Inks Record Number of Advance Agreements, Again

India signed a record number of advance pricing agreements in its just-ending fiscal year, blowing past last year’s record amid growing demand from taxpayers.

IRS Advance Pricing Agreement Backlog Grew After Departures

The IRS completed fewer advance pricing agreements last year after departures from the agency’s Advance Pricing and Mutual Agreement Program, worsening a growing backlog of pending agreements amid increased demand from taxpayers.

Practitioner Insights

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Five Questions With Jones Day Partner-in-Charge Colleen Laduzinski

Colleen Laduzinski

Jones Day

Five Questions With EisnerAmper Tax Partner Dean Peterson

Dean Peterson

EisnerAmper

Middle East Conflict Means Multiple Challenges for Tax Teams

Tuhin Chaturvedi

RSM in Kuwait

Latest Stories

Week in Insights: Work Opportunity Credit Never Really Worked

This week, experts examined a proposed California billionaire tax, VAT consequences of “zero-person” companies operated by AI, and more.

US Pricing Agreements Down, India’s Up: Transfer Pricing Report

Hello and welcome to the Transfer Pricing Report. I’m Caleb Harshberger, and it’s that time of year again: APA data! APMA’s annual report came out, showing the number of executed APAs are down at the office after departures last year. India, meanwhile, reported another record year of APAs signed. In the courts, the IRS appealed its Perrigo loss. And GE wins again in Italy.

Tax Pros Wonder About Outlook as IRS Pricing Agreements Slow

The diminished number of advance pricing agreements the IRS completed last year has tax practitioners wondering what the agency will do to get more APAs done with fewer resources.

Trump Restructures Broad Metals Tariffs But Keeps 50% Rate

The Trump administration said it will maintain 50% tariffs on many imported steel, aluminum and copper products, even as it moves to simplify duties for goods made with negligible amounts of the metals.

Interest Deduction Tweak Prompts Thoughts of Offshore Borrowing

American companies with a big global footprint are reconsidering their debt strategies in the US after a change in Republicans’ 2025 tax law that limits their ability to deduct interest expenses.

India Says PE Investments Before 2017 Won’t Face Extra Tax

Buyout firms sitting on billions of dollars of legacy assets in India got some relief this week, when the country’s finance ministry said it won’t apply anti-tax avoidance laws to investments made before April 1, 2017.

Pentagon Anthropic Deadlock Demands Thorough Checks on AI Use

When considering government AI use, lawmakers must pause immediate political incentives. This means establishing guardrails for what will best serve the country into the future.

US Tariff Refund Portal to Exclude One-Third of Imports at First

An online government portal to provide refunds on tariffs struck down by the US Supreme Court will handle claims for about 63% of 53 million import entries at issue when it first launches, according to a new court filing.

India Tax Office Inks Record Number of Advance Agreements, Again

India signed a record number of advance pricing agreements in its just-ending fiscal year, blowing past last year’s record amid growing demand from taxpayers.

Georgia Gas Tax Holiday Is Affordability Theater That Delays Harm

Lawmakers who want to soften rising gas prices’ impact on low- and middle-income households should deliver targeted relief measures that don’t disrupt markets.