C'est enfin des rituels complexes par lesquels vous ai et moi pouvons pactiser avec les dmons pour qu'ils nous enrichissent. (Mouslim). La volont de La notion de Bid'a en Islam. This cookie is set by ...

Patrick Donsimoni, La Boetie, discusses the February 2 decision of the French administrative Supreme Court that reveals the complexities of interpreting income tax treaties regarding the concept of ...

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 ...

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, 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 ...

Susi Baerentzen, Carlsberg Foundation Postdoctoral Fellow, discusses a recent transfer pricing ruling from the High Court of Eastern Denmark in a case on the application of the EU Arbitration ...

A US Internal Revenue Service “practice unit” released January 4 offers an overview of the rules relating to the dividends received deduction for certain foreign income of US corporations under ...

International tax researchers Noopur Trivedi and Jitesh Golani discuss key highlights of the OECD's much-awaited global anti-base erosion (GloBE) model rules, released on December 20, along with a ...

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 ...

Nour Ali, DNV, discusses Jordan's September 16 release of the country's latest transfer pricing guidance regarding the disclosure form, local file, master file, and country-by-country report, along ...

Horacio Sánchez Pangrazio, FERRERE, discusses Paraguay's October 14 and September 15 clarifications of its transfer pricing rules, providing further regulation regarding . . .