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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 ...
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 ...
Amanda Varma and Brigid Kelly of Steptoe & Johnson LLP, Washington, discuss the international tax provisions in the Tax Cuts and Jobs Act of 2017, including the new dividend-exemption system, the ...
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 ...
Rubeena Dina, Director at GTS Africa – Mauritius, discusses a Rwandan government ministerial order establishing general rules on transfer pricing . . .
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 ...
Emmanouela Kolovetsiou-Baliafa, KG Law Firm, discusses a Greek law retroactively reducing the corporate income tax rate, suspending of the special solidarity contribution (SSC), and introducing other ...
Susi Baerentzen, Carlsberg Foundation Postdoctoral Fellow, discusses the Danish Supreme Court's April 26 ruling in a landmark transfer pricing case involving a Danish company Tetra Pak that produced ...
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 ...