Scalar Conclusion: Recent Transfer Pricing Controversy Disputes , Decisions, and Agreements Global Transfer Pricing Enforcement: Multinationals Face Heightened Scrutiny Across the globe, tax authorities are stepping up enforcement of transfer pricing and cross-border transactions, targeting royalties, cost-sharing arrangements, and intercompany...

Bristol-Myers Sets $160 Million Tax Reserve for Transfer Pricing Bristol-Myers Squibb Increases Tax Reserves Amid IRS Transfer Pricing Dispute Issue:Bristol-Myers Squibb (BMS) is contesting several IRS proposed adjustments related to transfer pricing and other tax matters for the 2008–2012 tax...

French International Tax Audits Brought in €5.2 Billion France Reports Major Spike in Recovered Taxes, Driven by Transfer Pricing Audits Issue:France’s tax authority (DGFiP) released new audit results showing a surge in recovered unpaid taxes, with transfer pricing and other...

IRS Settlement Indicates Continuation of M&A Carveout Fights Microsemi Cost-Sharing Case Settles, Leaving Key Platform Contribution Questions Unanswered Issue:The Microsemi v. Commissioner case was expected to clarify how taxpayers should determine platform contribution transaction (PCT) payments when newly acquired intangible...

3M Case Marks Pathway for Coca-Cola’s Transfer Pricing Victory Coca-Cola Sees Opportunity in 3M Transfer Pricing Win Coca-Cola is fighting an IRS transfer pricing adjustment that could total up to $18 billion in taxes and interest. The dispute focuses on...

Medtronic Seeks Panel Rehearing of Transfer Pricing Decision 1. Issue & What Was at Issue Issue:Medtronic is seeking a rehearing from the Eighth Circuit after the court sided with the IRS in a transfer pricing dispute regarding the valuation of...