According to Resolution 37 from March 17, 2022, DIAN modified articles 4, 10, and 13 of 2021’s Resolution 164, which provided administrative regulation to articles 631-5 and 631-6 of the Colombian ...

The tax regimes of the six countries—the Kingdom of Saudi Arabia, the Kingdom of Bahrain, the State of Kuwait, the Sultanate of Oman, the State of Qatar and the United Arab Emirates—that make up the ...

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 ...

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 ...

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 ...

Ramon Bonell, Complutense University of Madrid, discusses the lessons that can be learned from the Spanish Tax Authority's December 16, 2021 challenge of the domestic withholding tax exemption on ...

Allan Lanthier, a former advisor to the Canadian government, warns it's time to hit the emergency brake on the OECD's model rules for Pillar Two; while close to 140 countries agreed to the October ...

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 ...

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 ...

The Zambia Revenue Authority on November 5 published an overview of tax measures in the Minister of Finance’s 2022 budget address, including changes to the corporate income tax rate and amendments to ...

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 ...

Noopur Trivedi and Jitesh Golani, international tax researchers, discuss how – out of the multiple design elements of the global minimum tax in the OECD/G20 July 1 statement – the adoption of ...