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Tighter Rules Issued on Adjustments for High-Value Intangibles
New IRS guidance clarifies that periodic adjustments are mandatory for high-profit intangible transactions and cost-sharing arrangements. The rule stresses using actual profit results for adjustments, not just arm's length estimates, and raises the bar for documentation.
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Focus Sharpens on Transfer Pricing for Intangible Asset Deals
The IRS is intensifying oversight of intangible asset transfers and related cost-sharing deals. The agency's updated approach expects reported results to reflect genuine economic substance and requires more thorough documentation of these complex transactions.
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IRS Boosts Enforcement and Penalties on Transfer Pricing Violations
The IRS has expanded its enforcement staff and put advanced analytical tools to work targeting transfer pricing compliance. Penalties can now reach as high as 40% for large adjustments, underscoring the need for companies to maintain meticulous records.
Economic Substance Principle Gains Traction in IRS Audits
IRS auditors are applying the economic substance doctrine more widely in transfer pricing reviews. Intercompany transactions must now clearly demonstrate a real business purpose, not just a tax benefit, or risk substantial penalties during IRS audits.
High-Profile Court Battles Emerge on Transfer Pricing Issues
Major U.S. corporations---as seen in new IRS cases involving Microsoft, Amgen, and Coca-Cola---are in legal disputes over the value of intangible assets and cost-sharing rules. These cases mark a tougher enforcement landscape for multinational enterprises.
Documentation and Disclosure Rules Tightened for 2025
The IRS now requires more detailed documentation for intercompany transactions. Companies must provide full transaction descriptions, identify all related parties, and justify their chosen transfer pricing methods, especially under the SSA and for intangibles.
The Big Tax Shakeup Decoding TCJA & OBBB with Anju Singh
Transfer pricing — the rules and methods for pricing transactions between related companies — has always been a complex challenge for multinational businesses. But now, artificial intelligence (AI) is stepping in, shaking up the world of international tax and compliance. Let’s explore how AI is changing transfer pricing, what opportunities it brings, and what hurdles remain.
AI Meets Transfer Pricing: How Smart Tech Is Revolutionizing Global Tax Compliance
If your company operates in more than one country, it probably buys, sells, or licenses goods and services between related parties. Setting the right prices for these internal transactions is crucial—not just for business reasons, but because tax authorities around the world want to make sure
The Big Tax Shakeup Decoding TCJA & OBBB with Anju Singh
If you’ve been following global tax news, you’ve probably heard about the OECD’s Pillar 1. In simple terms, it’s an international effort to update tax rules for our digital age. The idea? Make sure that the world’s biggest companies —especially tech giants—pay taxes not just where they’re headquartered, but also where their customers are.
Billion-Dollar Battles: 7 High-Profile Transfer Pricing Cases Every Business Should Know
Transfer pricing may not be breaking news on Wall Street, but in tax departments across the globe, it’s drawing headlines—and billion-dollar bills. As global tax authorities ramp up audits and crack down on profit shifting, several major multinationals
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