Transfer Pricing Case Laws
Amgen in Billion Dollar Transfer Pricing Dispute with the IRS
Amgen, in its quarterly report for the period ended March 31, 2022, disclosed that, not only has the group been issued a notice of assessments from the IRS for FY ...
Tokyo High Court rules in favour of NGK Insulators
In a decision issued on March 10, 2022 the Tokyo High Court upheld a 2020 decision from the district court and ruled mostly in favour of NGK INSULTATORS, LTD. in ...
OECD releases new 2022 edition of the OECD Transfer Pricing Guidelines
On 20 January 2022 the OECD released the 2022 edition of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations. The OECD Transfer Pricing Guidelines provide guidance on ...
Finnish TP-Legislation updated to include non-recognition and recharacterisation
Effective as of 1. January 2022 Finnish Transfer Pricing legislation has been updated to align the rules with the OECD Transfer Pricing Guidelines in regards to non-recognition and recharacterisation. Going ...
Swiss UBS bank to pay € 1,8 billion fine for “facilitation of tax evasion and money laundering”
The appeal court in Paris has confirmed that the Swiss UBS banking group is guilty of having facilitated tax evasion and money laundering in France, and on that basis the ...
EU directive on minimum effective tax rate – implementation of OECD Pillar II
The European Commission has proposed a Directive ensuring a minimum effective tax rate for the global activities of large multinational groups. The proposal delivers on the EU’s pledge to move ...
OECD releases Pillar Two model rules – Global Minimum Tax of 15%
The OECD has published detailed rules to assist in the implementation of a landmark reform to the international tax system, which will ensure Multinational Enterprises (MNEs) will be subject to ...
ResMed Inc has entered a $381.7 million tax settlement agreement with the Australian Tax Office
ResMed – a world-leading digital health company – in an October 2021 publication of results for the first quarter of FY 2022, informs that a $381.7 million tax settlement agreement ...