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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 ...

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 ...

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 ...

Dr. J. Harold McClure, a New York City economist, discusses the US Tax Court's November 18 ruling in a transfer pricing dispute between the IRS and Coca-Cola which considered the appropriate ...

Rubeena Dina and Aniruddha Saha, GTS Africa, discuss the global trend of tax authorities' introducing electronic invoicing requirements and the implications for transfer pricing in the Middle East and ...

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 ...

Amazon.com Inc on March 23 won a US Tax Court case, fending off IRS transfer pricing adjustments relating to payments under a cost-sharing agreement (CSA) with a Luxembourg subsidiary. The transfer ...

Davide Anghileri of the University of Lausanne discusses a European Court of Justice decision rendered July 25 holding that the Spanish tax lease system constitutes State aid and thus overturning a ...

Valeria Saavedra, Senior Associate, at Basefirma Venezuela, Caracas, discusses a new Paraguay law, effective January 1, which imposes income tax withholding on payments made to nonresidents that ...

Gian Luca Nieddu, Partner, Transfer Pricing & Tax Value Chain, Hager & Partners, Milan area, discusses a recent decision, of Italy's Supreme Court which addressed the VAT deductibility of intercompany ...

Aldo Engels, Loyens & Loeff, discusses the Belgian government’s recent decision to increase the effectiveness of transfer pricing audits of MNEs—followed by a new wave of transfer pricing audits ...