Transfer pricing refers to the pricing of goods, services and intellectual property transferred between related entities within a multinational corporation. Companies use transfer pricing to allocate ...

The Bureau of Internal Revenue (BIR) entered 2026 with an important shift in identifying taxpayers that will undergo tax audits. Revenue Memorandum Order (RMO) No. 12026 outlines a system-assisted, ...

In a pandemic environment, longstanding transfer pricing policies can lead to suboptimal tax results. Multinationals that incur losses in some locations while earning generous profits in others could ...

Internal Revenue Service sign with a traffic signal in the foreground indicating a red light. The IRS’ recent advice memorandum on periodic adjustments suggests that the agency may belatedly start ...

Some countries are considering making changes to their international tax laws on transfer pricing, and it may be wise for the United States to consider doing so as well. There is a pattern of ...

Transfer pricing refers to the prices charged for goods, services, and intellectual property (IP) between or among legal entities of a corporation, including a parent company and its domestic and ...

This article explores transfer pricing disputes with tax authorities and related disclosures in financial statements. Recent increases in companies’ risk exposure from these controversies have raised ...

Multinational oil and gas companies must think globally and act locally in order to comply with complex tax laws. To meet the growing global demand for oil and natural gas, international oil companies ...

It embodies the fundamental pricing calculation when services, tangible property and intangible property are bought and sold across international borders between related parties. The arm’s-length ...

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 ...