OrbitaxU.S. Court of Appeals Holds Transfer Pricing Rules May Not be Used to Reallocate Income a Taxpayer Cannot Legally Receive
|Approved Changes|United States
On 1 October 2025, the U.S. Court of Appeals for the Eighth Circuit issued a decision reversing a U.S. Tax Court decision in 3M Company v. Commissioner, a transfer pricing case involving royalty income from a Brazilian subsidiary in 2006. The dispute centered on royalties from 3M’s Brazilian subsidiary, which only paid USD 5.1 million for intellectual property used due to a cap under Brazilian…
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