Italian Free-Guarantee Ruling Boosts Transfer Pricing Toolkit

The Italian Supreme Court’s recent acceptance of a subsidiary’s no-fee guarantee for a parent company’s loan highlights what some tax practitioners see as growing willingness by courts to accept purely economic reasons for not charging intragroup fees, at least in the area of corporate finance.

Australia Needs More Tax Power for News, TV Broadcasters Say

The Australian Tax Office needs additional tools to discourage transfer pricing by tech companies hoping to avoid paying for local news content, the country’s commercial television broadcasters say.

IRS Says Periodic-Adjustment Memo Continues Arising in Audits

An IRS legal memo on the agency’s ability to adjust a company’s profits continues to come up in audits of companies’ transfer pricing, an IRS official said Wednesday.

EU Urges Luxembourg, Malta to Bolster Tax Dodging Deterrents

The European Commission pushed Luxembourg and Malta to strengthen measures against aggressive tax planning, warning both countries they’re susceptible to companies shifting profits to low-tax jurisdictions.

OECD Clarifies Intragroup Services in Proposed Guide Update

The OECD launched a public consultation Monday focused on updating transfer pricing guidance to clarify existing principles and provide practical examples for identifying and pricing intragroup services.

Latest Stories

Crypto Tokens Would Get New Tax Benefits Under House Bill

A House panel with jurisdiction over tax policy is preparing legislation that would grant cryptocurrency holders greater flexibility in reporting gains on investments, a potential boon for the digital asset industry.

Italian Free-Guarantee Ruling Boosts Transfer Pricing Toolkit

The Italian Supreme Court’s recent acceptance of a subsidiary’s no-fee guarantee for a parent company’s loan highlights what some tax practitioners see as growing willingness by courts to accept purely economic reasons for not charging intragroup fees, at least in the area of corporate finance.

Court Blocks Order for US Official to Testify on Tariff Refunds

A federal appeals court has for now suspended a judge’s order to compel Customs and Border Protection Commissioner Rodney Scott to testify about the Trump administration’s efforts to refund $166 billion in tariffs declared unlawful by the US Supreme Court earlier this year.

US Judge Warns DOJ Appeal Could Upend Trump Tariff Refunds

A US trade judge took the unusual step of personally responding to the Trump administration’s appeal of his order to refund $166 billion in tariffs the Supreme Court declared unlawful, calling the government’s filings “colorful” and questioning its legal stance.

Greer Says ‘Deal’s a Deal’ for Those With Capped US Tariffs

President Donald Trump’s trade chief signaled confidence the administration can roll out new tariffs without breaking terms of bilateral agreements, saying “a deal’s a deal” for economies like the European Union and Japan that negotiated caps on the US levies collected on their shipments.

Leading Law Firms: The Only Constant Is Change

Who are the leaders of the legal industry? Bloomberg Law’s Leading Law Firms list, now in its second year, recognizes the top performers across the key pillars of finance, growth, talent, and tech & innovation. The list identifies which firms—big or small, based in the US or abroad—are raising the bar for their competitors. Check out the list and dig in to the data now.

Tax Developments

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New Zealand, U.K. Sign New DTA, Protocol

The New Zealand Inland Revenue June 4 announced the June 1 signing of a new DTA and protocol with the U.K., which will replace the 1983 DTA and the 2003 ...

Sweden, Ireland Sign Second Protocol to 1986 DTA

The Swedish Ministry of Finance June 3 announced the same date signing of a second protocol to the 1986 DTA with Ireland. The protocol introduces new minimum standards for tax ...

Liechtenstein, Philippines Initial DTA

The Liechtenstein Fiscal Authority May 29 announced the same date initialing of a DTA with the Philippines. The DTA includes measures to: 1) incorporate the OECD’s base erosion and profit ...

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