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The long-awaited 2017 update to the United Nations Model Double Taxation Convention between Developed and Developing Countries was released last Friday during a UN Economic and Social Council meeting ...

Australia's Federal Court has handed the Australian Taxation Office (ATO) an important victory, concluding that USD 2.5 billion of loans between Chevron's Australian-resident company and its Delaware ...

Daniel Bunn, Tax Foundation, discusses why a meaningful tax hike for multinational companies has already been adopted while much of the policy focus has been on proposals embedded in the Build Back ...

Geoff Morris, InTP, provides an overview of Australia’s transfer pricing laws and the tax administration’s practices in this area, focusing on the provisions, as well as on how Australia monitors ...

Giuliana Polacco & Annarita De Carne, Studio Legale Bird & Bird, Milan, discuss the Italian Revenue Agency's long-awaited guidance issued on March 23 clarifying the application and implementation of ...

Vasiliki Koukoulioti, Newcastle University, discusses the UK Supreme Court's March 23 judgment that upholds the principle that the starting point in determining a company's profits and losses is the ...

This article examines the application of the arm’s length principle in the context of a related-party transaction that is characterized by integrated collaboration among decentralized business units ...

Allan Lanthier, a former advisor to the Canadian government, analyzes the recent treaty shopping decision of Trinidad and Tobago's Court of Appeal – a decision that stands in stark contrast to the ...

The Australian Taxation Office (ATO) and an Australian affiliate of US aluminum giant, Alcoa, are locked in a transfer pricing dispute over the price the affiliate charged a related Bahrain company ...

Aitor Navarro, Carlos III University, discusses the September 22 Spanish Supreme Court decision regarding SGL Carbon Holding (ECLI:ES:TS:2021:3572), addressing the denial of a mutual agreement ...

By Doug Connolly, MNE Tax The US Court of Appeals for the Sixth Circuit in a December 6 decision held that Whirlpool must pay taxes on more than USD 45 million in profits for which the appliance ...