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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 ...

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 ...

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 ...

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 ...

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 ...

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 ...

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 ...

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 ...

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 ...

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 ...