https://resources.comp-press.com/tags/obbba/Recent content in OBBBA on CompPress | Transfer Pricing ResourcesHugoen-usMon, 15 Dec 2025 00:00:00 +0000https://resources.comp-press.com/news/gilti-renamed-ncti-obbba-december-2025/Mon, 15 Dec 2025 00:00:00 +0000https://resources.comp-press.com/news/gilti-renamed-ncti-obbba-december-2025/<p>The One Big Beautiful Bill Act of 2025 (OBBBA), enacted in July 2025, renames the Global Intangible Low-Taxed Income (GILTI) regime as Net CFC Tested Income (NCTI) and modifies the operative parameters of the regime for tax years beginning after December 31, 2025. The rename is more than cosmetic: the OBBBA also resets the Section 250 deduction percentage and the effective US tax rate on the inclusion.</p> <p>For NCTI inclusions in tax years beginning after December 31, 2025, the Section 250 deduction is set at 40%. Combined with the headline 21% US corporate tax rate, this produces an effective US tax rate of approximately 12.6% on NCTI inclusions, before consideration of the foreign tax credit and the post-OBBBA expense allocation rules. The 90% foreign tax credit rate (i.e., the 10% haircut) on NCTI-related foreign taxes continues to apply, as do the rules requiring the allocation of a portion of US-incurred expenses against the NCTI basket.</p>https://resources.comp-press.com/articles/transfer-pricing-international-tax-architecture/Thu, 11 Dec 2025 00:00:00 +0000https://resources.comp-press.com/articles/transfer-pricing-international-tax-architecture/<p>Transfer pricing is one of several mechanisms in the international tax system for allocating multinational income across jurisdictions. It is the most analytically detailed of these mechanisms, but it is not the only one, and a transfer pricing position cannot be designed without reference to the others. This article surveys the broader architecture in which transfer pricing operates, identifies the principal interactions between transfer pricing and other international tax provisions, and illustrates one such interaction through a worked example. The discussion is global in framing, with US-specific provisions and OECD-aligned international rules treated together where each is most relevant.</p>