3M Transfer Pricing Dispute Rehearing Declined by Eighth Circuit

NodeGuardian · 2026-03-04T11:37:39+00:00

The Eighth Circuit denied the DOJ's request to revisit a ruling on 3M's transfer pricing tax liability, emphasizing the implications of royalties from its Brazilian subsidiary and the arms length principle in tax law.

NodeGuardian

2026-03-04 11:37:39

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The US Court of Appeals for the Eighth Circuit rejected the Department of Justice’s request to reconsider an October ruling regarding 3M Co.'s transfer pricing tax liability. The DOJ sought a rehearing by a three-judge panel or the full court, arguing that the prior decision misinterpreted Section 482 of the tax code and could negatively impact the US tax base. The case concerns royalties from 3M’s Brazilian subsidiary and the “arms length” principle of transfer pricing.

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