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Articles by Randall Fox
On progressives and ‘regressives’
In 1973, I turned 18, registered for the draft and registered to vote. My parents were Republicans but the 1960s and early ’70s, even viewed from backroads Nebraska, proved that there could be a better way and a hope for a life “non-parochial.” An anti-tea party protestor holds a sign with “Reality” and “Tea Party Meeting” pointing in opposite directions near the Wisconsin 2011 Tax Day Tea Party Rally.
Inside the 2025 IRS APMA Statistics
Trends and Implications for Multinational Tax Certainty Overview On 30 March 2026, the Internal Revenue Service (IRS) released Announcement 2026-8, the annual report on Advance Pricing Agreements (APAs) and the Advance Pricing and Mutual Agreement Program (APMA Program) for calendar year 2025.
UAE Offers Multinationals a Route to Tax Certainty with APAs Original
The United Arab Emirates has taken a decisive step toward strengthening tax certainty under its corporate tax regime with the release of long-awaited guidance on advance pricing agreements. The Federal Tax Authority has published its corporate tax guide on advance pricing agreements, formally putting into operation the APA framework introduced under the UAE’s corporate tax law.
Protecting NYC tax dollars using whistleblowers
For the incoming Mamdani administration to boost its affordability agenda, it must renew enforcement efforts to expose frauds against the city and recover millions of stolen taxpayer dollars. One key and neglected ingredient: whistleblowers. The city’s underutilized tool is the New York False Claims Act, a law that uniquely can generate actionable information about corrupt tax and contractor frauds that deplete city resources and sap confidence in government spending.
UK Budget 2025 - Introduction of an International Controlled Transactions Schedule | JD Supra
[co-author: Stephanie Pearson] Overview As part of the 2025 Autumn Budget announcements, the UK Government confirmed that it will introduce legislation requiring certain multinational enterprises to file an annual International Controlled Transactions Schedule (ICTS). The ICTS will require in-scope groups to disclose detailed information on their cross-border related-party transactions, forming a new layer of transfer pricing transparency and reporting.
HMRC clarifies approach to transfer pricing ranges – and why the median now matters | JD Supra
In November 2025, HMRC updated its International Manual (INTM485120), setting out a more structured approach to how case teams and taxpayers should apply ranges in transfer pricing analyses. The update clarifies HMRC’s expectations on the selection of comparables, the use of statistical tools such as the interquartile range (IQR), and the appropriate point within that range when a taxpayer’s results fall outside it.
OECD’s MAP and APA statistics. What 2024 has changed for Multinational Enterprises | JD Supra
[co-author: Stephanie Pearson] Introduction Last year, in our article “OECD’s 2023 MAP and APA Statistics: Key Insights for Multinational Enterprises”, we analysed the inaugural global statistics on Advance Pricing Arrangements (APAs) alongside the longstanding mutual agreement procedures (MAPs) data released by the Organisation for Economic Co‑operation and Development (OECD).
The Inclusive Framework released Additional Guidance on Amount B of Pillar One
As we discussed in a previous article, on 19 February 2024, the OECD published the report “Pillar One – Amount B: Inclusive Framework on BEPS”, aiming to simplify the application of transfer pricing rules regarding baseline marketing and distribution activities, reduce tax burden, and compliance costs, among other objectives, with a particular focus on low-capacity countries.
IRS APA and APMA Stats Announcement: Summary and Implications for International Clients Seeking Tax Certainty
Introduction The Internal Revenue Service (IRS) released Announcement 2024-16, which provides an annual report on the Advance Pricing Agreements (APAs) and the Advance Pricing and Mutual Agreement Program (APMA Program) for the calendar year 2023.
UK Tax Law Reform in Transfer Pricing, Permanent Establishment and Diverted Profits Tax
On 19 June 2023, the UK government published a consultation document aimed at modernising the UK tax rules for fairness, simplicity and growth.
Something Stinks
Something stinks about the entire City of Santa Barbara process in closing State Street. Where it is now closed to vehicles is part of El Pueblo Viejo Landmark District. And State Street has been open to vehicle traffic since cars first arrived here. “El Pueblo Viejo Landmark District is one of the most important areas to Santa Barbara, it is the home of our commercial corridor and its Spanish Colonial Revival style is key to the identity and beauty of Santa Barbara.
Brazil and UK sign tax treaty
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On 29 November 2022, Brazil and the UK signed a long-awaited Double Taxation Agreement (DTA). While the DTA will not enter into force until completion of the relevant legislative procedures required by Brazilian and UK law, which in Brazil requires the DTA to be approved by Congress and signed by the President, its implications are already relevant to multinationals which are, or are considering, operating in both jurisdictions.
By Alex Jorge, Matt Davies Verified, Randall Fox, Elizabeth Emerson, Victor Kampel, Cristiane Drumond, Tatiana Amba
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Lexology
Verified
Dispute Resolution Tools Offer Aid, Certainty to Multinationals Original
Buildings compose the skyline of Singapore on Oct. 2, 2022. Photographer: Lauryn Ishak/Bloomberg via Getty Images Dec. 7, 2022, 9:45 AM As the transfer pricing landscape evolves, alternative or advance dispute resolution tools can benefit taxpayers by providing certainty and eliminating double taxation, among other positive consequences, say DLA Piper’s Kevin Glenn, Rachit Agarwal, and Randall Fox.
DLA Piper adapts to clients’ needs, expanding TP practice across Europe
DLA Piper’s head of international transfer pricing, Randall Fox, appreciates how the greatest challenges may eventually lead to the greatest rewards. After moving across the pond to join the firm in June 2015, Fox was tasked with establishing and consolidating DLA Piper’s new TP practice in London. “I was looking for a new challenge,” Fox tells ITR.
Five Tax Whistleblowing Fallacies
As whistleblower-initiated tax cases under the New York False Claims Act expose more and more tax frauds—and legislators in California and other states consider replicating the law—opponents of tax whistleblowers have resorted to disprovable assertions and outright falsehoods about the law. But what are the facts?
Five Tax Whistleblowing Fallacies
As whistleblower-initiated tax cases under the New York False Claims Act expose more and more tax frauds—and legislators in California and other states consider replicating the law—opponents of tax whistleblowers have resorted to disprovable assertions and outright falsehoods about the law. But what are the facts?
HMRC Releases 2018/19 Data On Transfer Pricing And The Diverted Profit Tax
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Italy, Draft Regulation On Transfer Pricing And Corresponding Adjustments | JD Supra
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India publishes new rules for master file and CbC reporting
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Japan's National Tax Agency releases guidance on requesting Mutual Agreement Procedure assistance
The Japanese National Tax Agency (NTA) has released guidance for taxpayers on the mutual agreement procedure (MAP), in line with the recommendations of the OECD's Base erosion and profit shifting (BEPS) Action 14 Final Report. The guidance is intended to supplement the Commissioner's Directive on the Mutual Agreement Procedures, which contains the official administrative guidelines for requesting MAP assistance.
European Union adopts new Directive to better resolve double taxation disputes
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OECD releases reviews on BEPS Action 14
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Finland: Supreme Administrative Court decides two transfer pricing cases involving intra-group services - key takeaways
Finland's Supreme Administrative Court has published two new precedential decisions regarding transfer pricing rules, KHO:2017:145 and KHO:2017:146. Transfer pricing related rulings are in short supply in Finland and thus insights as to how the court views transfer pricing matters are welcome.
Morocco publishes new procedures for Advance Pricing Agreements
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Ireland's Revenue releases guidelines on requesting Mutual Agreement Procedure assistance
The guidelines, issued in early August, set out the legal basis for requesting MAP assistance as well as: The legal basis for requesting MAP derives from bilateral tax treaty provisions (typically negotiated based on article 25 of the OECD Model Tax Convention) signed by Ireland.
The Mutual Agreement Procedure: A Taxpayers' Tool Reinvented
Tax risks of multinational enterprises are expected to continue to increase post-BEPS as tax authorities globally increase their scrutiny on their cross-border tax transactions. This trend is anticipated in the OECD/G20 BEPS Action Plan: one of the Actions in it attempts to complement efforts to address BEPS with measures that ensure certainty and predictability for businesses in the face of increased tax controversy risks.
Tax administrations prepare for automatic exchange of CbC reports - are you ready? Three takeaways
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Russia introduces draft law on country-by-country reporting requirements: implications for multinationals
A newly published federal draft law introduces Russia to a three-tiered approach to transfer pricing documentation and brings Russian regulations in this area in line with the OECD minimum standards under Action 13 of the Base Erosion and Profit Shifting (BEPS) Action Plan. The draft law, published by the Ministry of Finance, is called the Documentation on Members of Multinational Corporate Enterprise Groups of Companies (MNEs).
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