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 ...

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 ...

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 ...

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, 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 ...

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 ...

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 ...

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 ...

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 ...

Dr. Harold McClure, a New York City economist, discusses how recently revised accounting standards for entities with leased assets impact the financial metrics often used in transfer pricing . . .