In this Bloomberg Tax article covering the expected challenges faced by global tax authorities and multinationals in the transfer pricing space over the next year, Anna Soubbotina is quoted noting that “multinationals will also be testing out new ways to fight transfer pricing adjustments in 2024 by taking disputes to forums where transfer pricing hasn’t traditionally been litigated like state courts.”
Who bore the tariff burden? Economics of IEEPA refund disputes
The refund question sits at the intersection of customs procedure, administrative law, but also economics, and resolution will likely vary significantly across...