MNE Tax

UN releases updated model tax treaty adding new technical services fees article

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 ...
MNE Tax

The new US international tax rules: what you need to know about GILTI, FDII, BEAT etc.

A new tax law (P.L. 115-97), often referred to as the Tax Cuts and Jobs Act of 2017 (Act), has dramatically modified the US international tax provisions, impacting both US and non-US headquartered ...
MNE Tax

Australian court rules Chevron’s intercompany loans were not arm’s length, imposes 25 percent tax penalty

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 ...
MNE Tax

OECD’s GloBE rules: Blending in with jurisdictional blending

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” for computation of effective tax rate ...
MNE Tax

How prudent is it to conduct transfer pricing risk adjustments for captive cost centres?

India’s Income Tax Appellate Tribunal recently set aside an order of the assessing authority in the case of GCO Technologies Centre Pvt Ltd (Case No. 6310/Mum/2014, dated 05.11.2020), in which the ...
MNE Tax

The lack of transfer pricing comparables: selecting the appropriate box of apples in which to find bananas

A draft toolkit addressing the lack of transfer pricing comparables was released for public comment in January by the Platform for Collaboration on Tax, a joint effort of the IMF, OECD, UN, and World ...
MNE Tax

“Synthesized text” of UK-Slovenia tax treaty reflects MLI changes

The UK government today released the synthesized text of the 2007 UK-Slovenia tax treaty, prepared jointly by the competent authorities of the UK and Slovenia, which reflects how the countries believe ...
MNE Tax

The US and Mexico’s transfer pricing approach for maquiladoras

The US and Mexico have agreed to renew their transfer pricing framework for US multinational enterprises that have maquiladora operations, according to a November 16 IRS announcement. The new ...
MNE Tax

Danish High Court rejects discretionary tax assessment in groundbreaking transfer pricing case

On March 28, the High Court of Eastern Denmark delivered its ruling in two joined cases between the former A.P. Møller – Mærsk group—then Mærsk Olie og Gas A/S and A.P. Møller-Mærsk A/S (hereafter ...
MNE Tax

New Cote D’Ivoire law clarifies country-by-country reporting, requires greater tax transparency

A Côte d’Ivoire law clarifying country-by-country reporting for multinational groups and addressing tax evasion through international investment was published in the official gazette December 27, 2019 ...
MNE Tax

Amazon wins $1.5 billion transfer pricing dispute in US Tax Court

Amazon.com Inc on March 23 won a US Tax Court case, fending off IRS transfer pricing adjustments relating to a cost-sharing agreement (CSA) buy-in payment. The transfer pricing adjustments would have ...
MNE Tax

The Evolution of Transfer Pricing in Saudi Arabia

The tax regimes of the six countries—the Kingdom of Saudi Arabia, the Kingdom of Bahrain, the State of Kuwait, the Sultanate of Oman, the State of Qatar and the United Arab Emirates—that make up the ...