The Presumption of Innocence Podcast: Episode 66 - Tariff Uncertainty and Compliance Risks for Businesses
GILTI Conscience Podcast | Beyond the Runway: Navigating Tax, Tariffs and Transfer Pricing in Luxury Fashion
GILTI Conscience Podcast | Navigating Brazil's New Transfer Pricing Landscape: A Shift to OECD Standards
GILTI Conscience Podcast | Navigating Permanent Establishments in International Tax Law
GILTI Conscience Podcast | Dissecting Cross-Border Transfer Pricing Resolutions
GILTI Conscience Podcast | Spotlight Series: Carving Your Path in Transfer Pricing
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
Transfer pricing enforcement is undergoing significant changes in both the United States and Ireland, with the two jurisdictions actively moving in different directions. While the United States is experiencing internal...more
The Trump administration’s fluctuating tariffs pose major compliance risks for businesses operating in the U.S. Dive into the challenges they pose to businesses that rely on imported goods and services as Marina Gentile...more
“GILTI Conscience” takes on the world of high-fashion, as Skadden tax partner and host David Farhat is joined by associate Stefane Victor and Giuseppe Abatista, vice president at Banca Popolare di Puglia e Basilicata, as they...more
Multinational groups adopting cost contribution arrangements (CCAs) — or cost share agreements in US parlance — as part of their cross-border intellectual property (IP) development strategies have a new opportunity to...more
International transactions, such as private equity deals, mergers and acquisitions, and financing arrangements, frequently leverage Luxembourg entities as holding companies or joint ventures. It is common for such companies...more
Join us for an insightful episode of “GILTI Conscience” as David Farhat, Eman Cuyler and Stefane Victor — together with our special host Skadden tax partner Loren Ponds and guest Fernando Colucci, partner at Machado Meyer in...more
On May 26, 2025, the Mexican Tax Administration Service (SAT) reported a 367% increase in tax revenue from large multinationals audits resulting from enforcing Mexico's transfer pricing rules. From 2019 through 2024, the...more
On 28 April 2025, HM Revenue and Customs (HMRC) proposed significant reforms to the UK’s transfer pricing and permanent establishment (PE) rules, and a repeal of the diverted profits tax, bringing that regime within UK...more
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for March 15, 2025 – March 28, 2025. IRS GUIDANCE - March 17, 2025: The IRS issued Revenue Ruling 2025-8, providing...more
Our latest episode of “GILTI Conscience” features an in-depth discussion on the complexities of profit attribution to permanent establishments (PEs) under international tax law. Skadden’s Nate Carden, David Farhat and Stefane...more
Why do international business dealings require integrated legal, tax, and accounting services? It doesn't matter how small or large your company is. If you are a U.S. company that conducts business outside of the United...more
Welcome to February’s edition of the UK Tax Round Up. This month has seen a number of interesting decisions covering the unallowable purpose test in relation to cross border group relief tax losses, the application of the...more
The global tax enforcement landscape is progressing rapidly, driven by regulatory changes, increasing cross-border collaboration, and shifts in funding for key tax authorities. Businesses operating in multiple jurisdictions...more
The “GILTI Conscience” podcast team, led by partners David Farhat and Nate Carden, hosted Clark Armitage of Caplin & Drysdale for an in-depth conversation on the various methods for resolving cross-border transfer pricing...more
The application of the arm's length principle (ALP) is not always easy or free from conflict between taxpayers and tax authorities and this is especially true for countries with low resources and limited reliable sources of...more
À la suite de la publication de l’édition 2023 du Guide des prix de transfert à l’usage des PME, l’administration fiscale a mis à jour ses commentaires au BOFiP relatifs aux principes de détermination des prix de transfert...more
HMRC has published a consultation paper anticipating reforms to the UK’s rules on transfer pricing, permanent establishments and diverted profits tax. This is a wide-ranging review and it may be that its constituent parts...more
For law students or young practitioners pursuing a career in tax law, there are numerous possibilities to gain hands on experience and knowledge. However, learning about and finding an entry into transfer pricing may be much...more
GRAs and Section 367(a)(1) Outbound Stock Transfer Rules Overview - Introduction to Section 367(a)(1), Outbound Stock Transfers, and Gain Recognition Agreements - Section 367(a) of the Internal Revenue Code (the “Code”)...more
International tax issues sit high on the political agenda for most countries. Among those issues, few rank higher than transfer pricing policies. Recent years have seen a trend toward Country-by-Country (CbC) reporting,...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
A decision in late-July 2022 of the UK’s Upper-tier Tax tribunal (“UTT”) has held that interest recognized by a UK resident company on loan notes issued to its parent was non-deductible under the UK transfer pricing rules, as...more
Intercompany transfer pricing is an IRS enforcement priority, and can result in significant tax liabilities and higher penalties than in many other situations. Federal tax laws provide avenues to reduce or eliminate the...more
US companies often have commercial transactions with their overseas affiliates in the form of financing, supply, manufacturing, services, or other agreements. Each of these common intercompany transactions can be the cause of...more