GILTI Conscience Podcast | Dissecting Cross-Border Transfer Pricing Resolutions
GILTI Conscience Podcast | An In-Depth Look at International Tax in Africa: Part 1
GILTI Conscience Podcast | Talking Transfer Pricing and the Arm’s Length Principle With Mike McDonald
The Issue Behind 'Almost All' Transfer Pricing Cases: Ex Ante or Ex Post Basis
Musings on Multinational Tax: What to Expect From GILTI Conscience
JONES DAY PRESENTS®: The Future of Transfer Pricing in Australia: Implications of the Glencore Decision
A precise definition of business services was recently at the core of a dispute between the Israel Tax Authority and eBay Marketplace Israel Ltd., a subsidiary of the multinational eBay Group. The district court litigated...more
The attractiveness of the United Kingdom as a business location is unabated. There are many advantages to doing business in the UK. Investors can draw on a skilled workforce and access a large market; costs of labour and...more
The Internal Revenue Service (IRS) recently released instructions for employees that may have the effect of deterring some companies from submitting advance pricing agreement (APA) requests. That, in turn, could introduce...more
The IRS has announced new rules relating to the acceptance of Advance Pricing Agreement (APA) and renewal requests. On April 25, 2023, the IRS published interim guidance (the Interim Guidance), effective as of that date, that...more
Join leading tax experts from across the globe, as we discuss tax trends that are reshaping international taxation - AN EXPERIENCE UNLIKE ANY OTHER - Find yourself on the cutting-edge of international tax law, with...more
In the new episode of our tax podcast, “GILTI Conscience,” EY’s Michael McDonald discusses whether the OECD’s DEMPE transfer pricing guidelines are being properly interpreted, including whether some jurisdictions are placing...more
In episode seven of "GILTI Conscience," hosts Nate Carden and David Farhat talk with Keystone Strategy's Bram Isgur about the issue underlying most major transfer pricing cases: whether to look forward to see what pricing...more
Skadden is proud to present "GILTI Conscience," a new podcast series in which tax partners Nate Carden and David Farhat invite other industry leaders and authorities to join them in discussing pressing transfer pricing...more
Join leading tax experts from across the globe, as we discuss tax trends that are reshaping international taxation - An Experience Unlike Any Other - Find yourself on the cutting-edge of international tax law, with...more
Medical device manufacturer, Medtronic, began its second trial on June 14 in the US Tax Court in a $1.36 billion transfer pricing dispute with the IRS. The trial concluded on June 25 and is among the most significant transfer...more
The Glencore decision is a landmark ruling on the application of Australia's transfer pricing rules governing transactions within multinational groups. These rules seek to ensure that tax is not avoided as a result of...more
During a 2019 Tax Executives Institute conference in Washington, D.C., the Commissioner of the U.S. Internal Revenue Service (IRS), Charles Rettig, proclaimed, “[I am] not a commissioner who believes that the IRS loses...more
Driven by ever-advancing technologies, today’s multinationals need to quickly adapt to new ways of doing business — a process that can often leave them more vulnerable to risk including tax and transfer pricing, especially...more
In 2019, a number of common themes emerged from cross-border transactions that have continued to demonstrate the impact of the 2014 Base Erosion and Profit Shifting (BEPS) actions. These themes, which we anticipate will gain...more
The policy behind SDIL is to reduce childhood obesity by encouraging producers to change the recipes and lower the sugar content of the drinks. The Government estimates that over 50% of manufacturers had done so before SDIL...more
OECD Note is Prelude to March Public Consultation on Global Tax Solutions - With the release January 29, 2019 of an important tax policy note (the “Note”), the Organization for Economic Cooperation and Development (the...more
The UK tax authority (HMRC) has announced a new Profits Diversion Compliance Facility (PDCF), as part of its efforts to ensure that multinationals do not use artificial arrangements to divert profit to lower tax...more
HMRC has announced today the introduction of a new Profits Diversion Compliance Facility, which is aimed at tackling the avoidance of tax by multinationals by diverting profits outside the UK without proper economic...more
HMRC announced today the introduction of their new Profits Diversion Compliance Facility (PDCF). This is a way for multinationals to take the initiative and explain their legal and operational structures before HMRC launch...more
On August 7, 2018, the Ninth Circuit withdrew its July 24 decision in Altera so that new panel member, Judge Susan P. Graber, can now consider the case....more
On July 24, 2018, in the Altera Corp v. Commissioner decision, the Ninth Circuit overturned a 2015 U.S. Tax Court opinion and upheld the validity of regulations requiring taxpayers to treat stock-based compensation as a cost...more