As mentioned in class, transfer pricing is becoming an increasingly complex and confrontational issue as tax authorities around the globe are struggling to collect as much money as possible.  Companies, meanwhile, are increasingly operating in multiple jurisdictions and have certain leeway with regard to pricing internal transfers, which tax authorities (including the IRS) may disagree with.

CFO.com profiled a transfer pricing case earlier this week involving Veritas, a software firm that is now part of Symantec, and the IRS.

Veritas Scores a Major Transfer-Pricing Victory. The tax court sides with the software company against the IRS. Robert Willens – CFO.com. December 21, 2009