By Francesca Amaddeo, Researcher, Tax Law Competence Centre (SUPSI), Manno, Switzerland On 4 June, the Platform for Collaboration on Tax, a joint initiative of the IMF, OECD, UN, and World Bank Group ...

By Noopur Trivedi and Jitesh Golani Out of the multiple crucial design elements of the global minimum tax under Pillar Two of the OECD/G20 July 1 statement, the adoption of “jurisdictional blending” ...

By Oliver Treidler, Tom-Eric Kunz, Maximilian Capraro, and Michael Dorner [1] Most contemporary developments in transfer pricing relate to intangibles. Appropriately coping with increasingly highly ...

By Noopur Trivedi and Jitesh Golani Today, the OECD released the much-awaited global anti-base erosion (GloBE) model rules with a commitment to finalize the commentary and safe harbors in early 2022.

By Geoff Morris, Transfer Pricing Advisor, Director, Independent Transfer Pricing (InTP), Melbourne, Australia Australia is one of the Group of Twenty nations that delivers internationally-coordinated ...

by Julie Martin 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 ...

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 ...

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 ...

By Ashish Mehta, Partner, and Sanket Shah, Principal Associate, Khaitan & Co., Mumbai The Indian tax administration on 10 August issued rules for computing relief related to the tax on book profits in ...

By Daniel Bunn, Vice President of Global Projects, Tax Foundation, Washington, D.C. Throughout the first year of the Biden administration, one tax policy theme was consistent. The President and ...

By Giuliana Polacco & Annarita De Carne, Studio Legale Bird & Bird, Milan The Italian Revenue Agency, on March 23, issued long-awaited guidance clarifying the application and implementation of the ...

By Vasiliki Koukoulioti, Lecturer in Law at Newcastle University, Newcastle upon Tyne, England In its judgment of March 23 in Commissioners for Her Majesty’s Revenue and Customs v NCL Investments Ltd ...