Transfer Pricing
OECD blesses exemption of qualified “side-by-side” regimes from the application of Pillar 2’s IIR and UTPR taxes
Yesterday, January 5, 2026, the OECD announced several revised safe harbors, including one that reflects an agreement to allow multinational entity groups (“MNEs”) with ultimate parent entities (“UPEs”) that are…
Read MoreUnlocking Export Tax Savings: A Modern Guide to IC-DISCs and How to Use Them Effectively
In today’s global marketplace, many U.S. businesses miss a hidden gem of tax savings. Originating in law enacted in 1971, it offers exporters a powerful, but often misunderstood tool for…
Read MoreMedtronic, Eighth Circuit Ruling, Best Methods and the Theory of the Firm
Scott Montopoli leads KBF’s International Tax Services with a focus on cross-border tax planning and compliance. Jonathan Voll leads KBF’s Transfer Pricing Services with a focus on intangible assets management…
Read MoreHigh Court Win for PepsiCo – Implications for Multinationals
The High Court of Australia has handed PepsiCo Inc. a significant victory in a closely watched cross-border tax case. In a 4–3 decision, the court dismissed the Australian Taxation Office’s…
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