Alex M. Parker, Capitol Counsel LLC, discusses why last year’s OECD-G20 global minimum tax agreement has revealed a scope much broader than most anticipated; provisions of the agreement, revealed in ...

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 ...

Oliver Treidler and Tom-Eric Kunz, TP&C, analyze the current transfer pricing landscape in Germany, following the plethora of updates to regulations and administrative principles in 2020 and 2021, ...

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 ...

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 ...

EU member states are at odds on various issues related to the directive to implement within the EU the global minimum tax portion of the OECD agreement, with several members expressing concerns about ...

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 ...

Luca Tortorella and Michele Targa, Gatti Pavesi Bianchi Ludovici, discuss the Italian revenue agency's November 26 release of Circular No. 15/E clarifying new instructions relating to amended transfer ...

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 ...

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 ...