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EY Global Tax Controversy Flash Newsletter (Issue 73) | Recent developments reinforce importance of reviewing transfer pricing approach

09 September 2024

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Tax Alerts, Legislation & Policy, Transfer Pricing, Global

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United States, Albania, Andorra, Angola, Argentina, Australia, Austria, Bahamas, Bahrain, Bangladesh, Barbados, Belgium, Bolivia, Botswana, Brazil + 133 more

In the United States, the IRS has escalated its approach to companies that did not respond to transfer pricing compliance letters by referring them for potential examination. Taxpayers should continue to monitor the progress of this transfer pricing compliance initiative as it may provide insight into future IRS initiatives. An EY Tax Alert has more details.In Loper Bright Enterprises v. Raimondo, No. 22-451 (28 June 2024), the U.S. Supreme Court overruled Chevron deference, now requiring courts to independently interpret statutes rather than deferring to agency interpretations. This significant change affects regulatory compliance and could have far-reaching implications for taxpayers and...