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TODAY'S ISSUES

GTC Quarterly

Find out the latest Global Tax Controversy Cases 

GTC Global
Nov 12, 20251 min read

U.S. Court Tightens Transfer Pricing Rules in 3M Intangibles Case

October 1, 2025 The U.S. Court of Appeals revisited disputes over the valuation of intangible property transferred to foreign affiliates under a cost-sharing arrangement. The IRS contended that 3M understated the value of its intangibles, failing to meet the “commensurate with income” standard of IRC Section 482. The Court upheld the IRS’s income-based valuation, recognizing the use of post-transaction profit evidence to test arm’s length results. By endorsing the IRS’s appro

GTC Global
Nov 5, 20251 min read

Swiss Court Tightens Scrutiny on Intra-Group Service Charges

May 2023 The Swiss Federal Administrative Court assessed the deductibility of intercompany service fees and management charges between two related entities. The Swiss tax authority argued the charges lacked commercial justification and duplicated group-wide services, asserting they failed the arm’s length principle. The Court agreed, concluding the taxpayer did not sufficiently prove measurable benefits arising from the services rendered. By affirming the tax authority’s posi

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