Hello and welcome to the Transfer Pricing Report. I’m Caleb Harshberger, and this week we take a look at where Germany and China are in talks to bring APAs back between them. An action-packed IFA event featured practitioners and in-house tax pros talking about the latest in TP and related international tax topics. And the OECD’s ICAP nabs its 25th nation.

German multinationals are holding out hope that tax officials and China’s government can break an impasse over cross-border transfer pricing arrangements as the countries restart negotiations over a path to more tax certainty.

The OECD has handed tax authorities a robust, treaty-sanctioned framework to attack excessive debt financing, meaning corporate tax directors must ensure every intercompany financial transaction is backed by rigorous analyses, says STI Taxand’s Christos Theophilou.

The Chinese government published guidance for its companies subject to the global minimum tax in Ireland, Denmark, and the United Arab Emirates.

International tax scrutiny is intensifying, with disputes increasingly focused on intangibles, cross-border structures, and the correct characterization of royalties, says Baker McKenzie’s Antonio Weffer.

The Trump administration said the first tariff refund payment is set to go out around May 11, even as thousands of US importers encounter issues with a new online portal designed to handle claims on the $166 billion in dutiesthat were overturned by the Supreme Court.