MNE Tax

Stay up to date on the latest tax and transfer pricing news
with our free newsletter   Sign Up Now  

MENUMENU
  • Home
  • Latest
  • Transfer Pricing
  • Digital Economy
  • Multinational
    • All Multinational
      • BRICS
      • CIAT
      • G20
      • G7
      • Holy See
      • Inclusive Framework on BEPS
      • International Monetary Fund
      • OECD
      • United Nations
      • World Bank Group
      • World Trade Organization
  • Africa
    • All Africa
      • Algeria
      • Angola
      • Benin
      • Botswana
      • Burkina Faso
      • Cabo Verde
      • Cameroon
      • Congo
    • -----
      • Côte d’Ivoire
      • Guyana
      • Djibouti
      • Egypt
      • Ethiopia
      • Gabon
      • Ghana
    • -----
      • Montserrat
      • Kenya
      • Lesotho
      • Liberia
      • Malawi
      • Mali
      • Mauritius
    • -----
      • Morocco
      • Namibia
      • Nigeria
      • Rwanda
      • Senegal
      • Seychelles
      • Sierra Leone
    • -----
      • South Africa
      • South Sudan
      • Swaziland
      • Tunisia
      • Uganda
      • Zambia
      • Zimbabwe
  • Americas
    • All Americas
      • Anguilla
      • Antigua and Barbuda
      • Argentina
      • Aruba
      • Bahamas
      • Barbados
      • Belize
      • Bermuda
      • Bolivia
    • -----
      • Brazil
      • Canada
      • British Virgin Islands
      • Cayman Islands
      • Chile
      • Colombia
      • Costa Rica
      • Cuba
      • Curacao
    • -----
      • Dominica
      • Dominican Republic
      • Ecuador
      • El Salvador
      • Grenada
      • Guatemala
      • Haiti
      • Honduras
      • Nicaragua
    • -----
      • Saint Lucia
      • Jamaica
      • Mexico
      • Panama
      • Paraguay
      • Peru
      • Saint Kitts and Nevis
      • Saint Martin
      • Saint Vincent and the Grenadines
    • -----
      • St. Lucia
      • Suriname
      • Trinidad and Tobago
      • Turks and Caicos Islands
      • United States
      • Uruguay
      • US Virgin Islands
      • Venezuela
  • Asia-Pacific
    • All Asia-Pacific
      • American Samoa
      • Armenia
      • Australia
      • Azerbaijan
      • Bahrain
      • Bangladesh
      • Bangladesh
      • Bhutan
      • Brunei
      • Cambodia
      • China
      • Cook Islands
      • Fiji
      • Georgia
    • -----
      • Guam
      • Hong Kong
      • India
      • Indonesia
      • Iran
      • Iraq
      • Israel
      • Japan
      • Jordan
      • Kazakhstan
      • Kiribati
      • Kyrgyzstan
      • Kuwait
    • -----
      • Laos
      • Lebanon
      • Macau
      • Malaysia
      • Maldives
      • Marshall Islands
      • Mongolia
      • Myanmar
      • Nauru
      • Nepal
      • New Zealand
      • Niue
    • -----
      • Oman
      • Pakistan
      • Palau
      • Papua New Guinea
      • Philippines
      • Qatar
      • Samoa
      • Saudi Arabia
      • Singapore
      • Solomon Islands
      • South Korea
    • -----
      • Sri Lanka
      • Taiwan
      • Thailand
      • Tonga
      • Turkey
      • Turkmenistan
      • Tuvalu
      • United Arab Emirates
      • Uzbekistan
      • Vanuatu
      • Vietnam
  • Europe
    • All Europe
      • Albania
      • Andorra
      • Austria
      • Belarus
      • Belgium
      • Bulgaria
      • Council of the European Union
      • Croatia
      • Cyprus
      • Czech Republic
      • Denmark
    • -----
      • Estonia
      • European Commission
      • European Council
      • European Court of Justice
      • European Parliament
      • Faroe Islands
      • Finland
      • France
      • Germany
      • Gibraltar
      • Greece
    • ----
      • Greenland
      • Guernsey
      • Hungary
      • Iceland
      • Ireland
      • Isle of Man
      • Italy
      • Jersey
      • Kosovo
      • Latvia
      • Liechtenstein
    • ----
      • Lithuania
      • Luxembourg
      • Macedonia
      • Malta
      • Monaco
      • Norway
      • Poland
      • Portugal
      • Romania
      • Russia
      • San Marino
    • -----
      • Serbia
      • Slovakia
      • Slovenia
      • Spain
      • Sweden
      • Switzerland
      • The Netherlands
      • Ukraine
      • United Kingdom
MENUMENU
  • International Tax and Transfer Pricing Expert Authors
    • Americas
      • Argentina
      • Brazil
      • Canada
      • Chile
      • Colombia
      • Dominican Republic
      • Mexico
      • Panama
      • Paraguay
      • Peru
      • United States
        • Atlanta
        • DC area
        • California
        • Florida
        • Illinois
        • Massachusetts
        • New York
        • Pennsylvania
        • Washington
      • Uruguay
    • Europe
      • Austria
      • Belgium
      • Bulgaria
      • France
      • Croatia
      • Cyprus
      • Denmark
      • Estonia
      • Finland
      • France
      • Germany
      • Greece
      • Iceland
      • Ireland
      • Italy
      • Lithuania
      • Luxembourg
      • Netherlands
      • Norway
      • Poland
      • Portugal
      • Romania
      • Russia
      • Serbia
      • Spain
      • Sweden
      • Switzerland
      • Ukraine
      • United Kingdom
    • Asia-Pacific
      • Australia
      • Azerbaijan
      • Bahrain
      • Cambodia
      • China
      • Georgia
      • Hong Kong
      • India
      • Israel
      • Japan
      • Jordan
      • Maldives
      • Pakistan
      • Philippines
      • Singapore
      • South Korea
      • Sri Lanka
      • Thailand
      • Turkey
      • United Arab Emirates
      • Vietnam
    • Africa
      • Benin
      • Côte d’Ivoire
      • Egypt
      • Kenya
      • Mauritius
      • Morocco
      • Nigeria
      • South Africa
      • Zimbabwe

Americas

Americas

Country-by-country reporting exchange agreement between US and Slovenia available

June 15, 2018

The US IRS today made available on its website a country-by-country reporting exchange . . .

Americas

IRS offers penalty, filing relief for new transition tax on foreign earnings 

June 7, 2018

The US IRS on June 4 announced that it will waive some late-payment penalties relating to the section 965 transition tax, which deems a repatriation by US shareholders of overseas earnings held by offshore companies. Guidance was also provided for individuals . . .

Americas

Trump administration to propose “reciprocal tax” on imports to counter unfair practices as soon as this week: Jordan Fabian / The Hill→

February 14, 2018
No Picture
Americas

US off EU tax have blacklist despite failing transparency criteria:  Joe Kirwin / Bloomberg BNA→

November 13, 2017
Americas

US, Mexico sign agreement to exchange country-by-country reports on multinationals

October 26, 2017

The US and Mexico have agreed to exchange country-by-country tax reports on multinational firms, implementing 2015 OECD/G20 base erosion profit shifting (BEPS) plan agreements, US Treasury . . .

Americas

Linguanti leaves Baker McKenzie to join Morgan Lewis’s Chicago tax practice

August 9, 2017

Thomas V. Linguanti has joined Morgan, Lewis & Bockius LLP as a partner in Chicago, the firm announced August 8. Linguanti, formerlly chair of Baker & McKenzie LLP’s North . . .

Americas

US, Israel to renegotiate tax treaty withholding rates: Hagai Amit / Haaretz→

July 26, 2017
Americas

WTO again rules Washington State business tax reduction benefiting Boeing is illegal: Dominic Gates / The Seattle Times→

June 15, 2017
Americas

US, Bahrain sign Model 1 FATCA IGA

January 18, 2017

The US Treasury Department today updated its FATCA website, reporting that Bahrain and the US signed a Model 1 intergovernmental . . .

Americas

US, Grenada sign Model 1 FATCA IGA

December 6, 2016

The US Treasury Department has updated its FATCA website, reporting that Grenada and the US have signed a Model 1 intergovernmental . . .

Africa

Multinationals asked to assess MAP tax dispute resolution in US, UK, Belgium, Canada, Netherlands, Switzerland

October 31, 2016

The OECD has today asked international business to report grievances about the mutual agreement procedure (MAP) for resolving cross-border tax disputes in the US, UK, Belgium, Canada, Netherlands, and Switzerland. The OECD seeks responses to a . . .

Americas

IRS’s “no rule” list updated to allow private tax rulings on distributions of stock of controlled corporations

August 26, 2016

The US IRS today updated its “no rule” list of topics that the agency will not ordinarily address in private letter rulings or determination letters, taking two issues off the list that relate to distributions of stock of controlled corporations under . . .

Americas

IRS says Facebook’s valuation of IP transfer to Ireland may have been understated by billions of dollars

July 7, 2016

A US Department of Justice lawsuit filed in Federal court on Wednesday reveals that the IRS believes that Facebook may have significantly undervalued a transfer of intellectual property . . .

Americas

More multinationals applying for US advance pricing agreements, statistics show

March 31, 2016

The US IRS on March 31 released statistics on the performance of the IRS’s Advance Pricing Mutual Agreement Program (APMA), revealing that taxpayers submitted . . . 

Asia-Pacific

Japan, Uruguay to negotiate tax treaty

April 8, 2019

apan’s Ministry for Finance has today announced that . . .

Americas

Marjorie Rollinson rejoins EY as Deputy Director of National Tax

March 7, 2019

Former US IRS Associate Chief Counsel (International) Marjorie Rollinson has rejoined . . .

Africa

G20 leaders seek improved international tax system based on tax treaties, transfer pricing rules

December 3, 2018

G20 leaders, in a communique issued after their summit in Buenos Aires, Argentina, reaffirmed their commitment to improving the international tax system . . .

Americas

Canadian appeals court overturns decision in Univar, concludes GAAR does not apply to paid-up-capital planning during acquisition: EY→

October 23, 2017
Americas

US to exchange country-by-country reports with Australia, Estonia

August 3, 2017

The US IRS today announced that it has entered into separate agreements with Australia and Estonia to exchange country-by-country reports . . .

Africa

US has agreed to country-by-country tax info exchange with 11 countries, OECD says

June 22, 2017

The United States has so far put in place 11 bilateral competent authority arrangements for the automatic exchange of country-by-country reports, the OECD reported a June 22 release. The US now has . . .

Americas

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

March 24, 2017

Amazon.com Inc on March 23 won a US Tax Court case, fending off IRS transfer pricing adjustments relating to payments under a cost-sharing agreement (CSA) with a Luxembourg subsidiary. The transfer pricing adjustments would have increased. . . 

Americas

UVA professor analyzes tax EU State aid law as applied to tax rulings: Ruth Mason / SSRN→

March 1, 2017

See: SSRN.

Americas

Mnuchin sworn in as US Treasury Secretary

February 13, 2017

Steven T. Mnuchin was sworn in to serve as US Secretary of the Treasury on February 13. In this capacity, Mnuchin will be the principal. . .

Americas

US IRS issues FATCA regulations, updates agreements for FFIs, QIs

January 3, 2017

The US IRS in late December issued a slew of FATCA guidance, including updated agreements for foreign financial institutions and qualified intermediaries (QIs). Included in the release were . . .

Americas

WTO ruling prohibits Boeing’s Washington State tax break: BBC News→

November 28, 2016

See: BBC News. More: CBS News, Wall Street Journal, Seattle Times. Original Source: WTO.

Americas

US Supreme Court denies certiorari in Gillette case which held MTC apportionment formula not binding on California: Lawrence Hurley / Reuters→

October 11, 2016

See: Reuters.

Americas

Japan, Panama sign tax information exchange agreement regarding Panama City

August 26, 2016

In an effort to combat tax evasion, Japan and Panama have signed a tax information exchange agreement relating to tax matters in Panama City, Japan’s . . .

Americas

Authors address US model tax treaty special tax regimes, subsequent law changes: Allison Christians & Alexander Ezenagu / SSRN→

May 20, 2016

See: SSRN

Americas

80+ US companies urge Congress to ratify pending tax treaties citing double taxation concerns: National Foreign Trade Council→

April 30, 2019
American Samoa

Netherlands publishes tax ‘blacklist’ for CFC rules

January 8, 2019

Jian-Cheng Ku, Robin Theuns, and Rhys Bane of DLA Piper Nederland N.V., discuss the Dutch Ministry of Finance’s blacklist of low tax jurisdictions for controlled foreign company purposes. published December 28, 2018 . . . 

Americas

US IRS issues proposed BEAT regulations

December 13, 2018

The US Internal Revenue Service today issued proposed regulations on the new base erosion and anti-abuse tax (BEAT) . . .

Americas

Brazil guidance addresses treatment of brand name, know-how under Brazil-France tax treaty

November 7, 2018

Francisco Moreira of Bichara Advogados, São Paulo, discusses an October 2 Brazilian tax authority ruling addressing the tax treatment of payments for brand name and know-how under the Brazil-France tax treaty . . .

No Picture
Africa

EU adjusts tax blacklist for Liechtenstein, Peru, Palau

October 2, 2018

The EU’s Economic and Financial Affairs Council (ECOFIN) today updated the EU’s blacklist of non-cooperative jurisdictions in taxation matters . . .

Americas

Chile’s customs now accepts value set in APA: KPMG→

August 18, 2018
Americas

US threatens 25 percent tariff on Chinese imports containing industrial significant technology: Zhenhua Lu / South China Morning Post→

May 30, 2018
Americas

US omnibus bill enacted, includes tax corrections but only one TCJA fix: Grant Thornton→

March 23, 2018
Americas

Germany’s new government signals paradigm shift in international tax policy

February 7, 2018

Ninja-Antonia Reggelin discusses the German coalition government agreement, reached today, which appears to signal a significant change in Germany’s international tax policy . . .

Americas

Royal Dutch Shell, Barclays to show billions in paper losses from deferred tax assets drop due to US tax reform: Brady Quigley / Equities Focus→

January 4, 2018
Americas

US Congress approves tax reform bill

December 20, 2017

The US House of Representatives today gave final approval to to sweeping tax reform, agreeing to a Senate Amendment to H.R. 1. by a vote of 224 to 201. In addition . . .

Posts navigation

« 1 … 32 33 34 … 53 »

What’s Next

May 19 – 20Tax Council Policy Institute ConferenceWashington, D.C.
May 19 – 20IFA Second European Region ConferenceMilan, Italy
May 24IFA Webinar Series Pillar Two: An UpdateVirtual Event
Sept. 4 – 8IFA CongressBerlin
Add Your Event
RECENT COMMENTS
  • Khaled Al Zaabi on Spanish government proposes digital services tax: “We are seeking assistance with Digital Assets and International Tax Consulting to help Abu Dhabi UAE Oil Company navigate the…” October 24 ,2024
  • Emma Hinson Sims on The Pillar One blueprint — the potential future of international taxation and transfer pricing: “HAPPY BIRTHDAY TO A VERY SMART, BEAUTIFUL, YOUNG LADY ON JANUARY 13TH.” January 6 ,2024
  • David Valdez on US Tax Court resolves Whirlpool tax dispute involving Mexican maquiladora structure: “Greetings Whirlpool Mexico, I’m trying to contact someone involved with the decision making for transportation from all of your Mexican…” October 20 ,2023
  • Jose Dominguez on The new US international tax rules: what you need to know about GILTI, FDII, BEAT etc.: “Very informative article. Question. Do you have a software to compute these US International Calcs to make them in house?” April 12 ,2023
  • Ciro César Soriano de Oliveira on Danish High Court rules on beneficial ownership of dividends for tax purposes: “Dear Ms Susi, This article is immensely clarifying. I’d like to know whether Danish Supreme Court has already granted its…” March 24 ,2023

OUR INTERNATIONAL TAX AND TRANSFER PRICING EXPERT AUTHORS
More than 300 international tax and transfer pricing experts from around the the world have published with MNE Tax. You can find listing of our authors below:

Europe
Austria
Belgium
Bulgaria
Croatia
France
Germany
Ireland
Italy
Luxembourg
Netherlands
Norway
Poland
Spain
Sweden
Switzerland
Ukraine
United Kingdom

Asia-Pacific
Australia
Cambodia
China
Georgia
Hong Kong
India
Israel
Japan
Singapore
Turkey
UAE
Vietnam

Americas
Argentina
Brazil
Canada
Chile
Canada
Mexico
Peru
United States
□ California
□ DC area
□ Florida
□ Illinois
□ Massachusetts
□ New York
□ Pennsylvania
□ Washington
Uruguay 

Africa
Benin
Côte d’Ivoire
Mauritius
South Africa
Zimbabwe

For information about publishing with MNE Tax, please visit this link.

Sign up for FREE Updates:

Don't miss the latest tax & transfer pricing news!
Sign up now
  • My account

Search MNE Tax

Latest

  • Policy Paper: Transfer pricing documentation
    July 26, 2022
  • Indonesia Taxes Crypto Asset Transactions
    July 12, 2022
  • New CbC Reporting Requirements to Apply in Kenya
    July 7, 2022
  • The Colombian National Tax and Customs Administration (DIAN) modified 2021’s Resolution 164 related to the Ultimate Beneficial Owner´s Report (RUB).
    July 5, 2022
  • Frustrated with Congress, Intel delays chips groundbreaking ceremony
    June 28, 2022
  • Finnish Tax Administration to Publish Guidance on Reverse Hybrid Legislation
    June 28, 2022
  • The Evolution of Transfer Pricing in Saudi Arabia
    June 23, 2022
  • The Functional Analysis—What You Need to Know
    June 22, 2022
  • How International Organizations are Changing Transfer Pricing Compliance
    June 22, 2022
  • UK delays Pillar 2 of global tax rules to December
    June 22, 2022
  • The OECD’s Tax Transparency in Africa 2022: Africa Initiative Progress Report
    June 22, 2022
  • Mutual Agreement Procedures (MAP) and Tax Treaties benefit grant General Rules under public consultation in Dominican Republic
    June 21, 2022

Recent Comments

  • Khaled Al Zaabi on Spanish government proposes digital services tax: “We are seeking assistance with Digital Assets and International Tax Consulting to help Abu Dhabi UAE Oil Company navigate the…” October 24 ,2024
  • Emma Hinson Sims on The Pillar One blueprint — the potential future of international taxation and transfer pricing: “HAPPY BIRTHDAY TO A VERY SMART, BEAUTIFUL, YOUNG LADY ON JANUARY 13TH.” January 6 ,2024
  • David Valdez on US Tax Court resolves Whirlpool tax dispute involving Mexican maquiladora structure: “Greetings Whirlpool Mexico, I’m trying to contact someone involved with the decision making for transportation from all of your Mexican…” October 20 ,2023
  • Jose Dominguez on The new US international tax rules: what you need to know about GILTI, FDII, BEAT etc.: “Very informative article. Question. Do you have a software to compute these US International Calcs to make them in house?” April 12 ,2023
  • Ciro César Soriano de Oliveira on Danish High Court rules on beneficial ownership of dividends for tax purposes: “Dear Ms Susi, This article is immensely clarifying. I’d like to know whether Danish Supreme Court has already granted its…” March 24 ,2023

R&D Tax Credit News

  • Muddled goals, broad scope lead to unexpected costs of OECD tax agreement
    April 20, 2022
  • US House of Representatives Ways and Means Committee Republicans reintroduce R&D-related legislation: Committee on Ways and Means→
    April 20, 2022
  • Irish Department of Finance seeks public comments by May 30 on research & development (R&D) tax credit and the `Knowledge Development Box,’ an OECD-compliant intellectual property regime, which provides relief from corporation tax on income arising from qualifying assets, such as computer programs and inventions protected by a qualifying patent: Irish Ministry of Finance→
    April 18, 2022
  • What does the Marijuana Opportunity Reinvestment and Expungement Act mean for the R&D tax credit?
    April 7, 2022
  • South Africa’s R&D Catch-22: Lydia Clowney / CrossBorder Solutions→
    April 6, 2022

Accounting & Reporting News

  • Calls are increasing for company disclosures on tax to help build public trust and fit in with environmental, social and governance (ESG) agenda: Aidan Lucey / The Irish Times→
    April 20, 2022
  • Will Amazon’s investors make the rules on tax transparency more clear?: CrossBorder Solutions→
    April 13, 2022
  • US Senate Finance Committee Chair Ron Wyden requests pharmaceutical company Merck explain its tax accounting practices, as it reports just 14% of pretax income in the US despite US market being home to 46% of global sales: Ron Weyden / US Senate Committee on Finance→
    April 5, 2022
  • UK Supreme Court holds on the tax deductibility of employee share options required under IFRS 2
    March 29, 2022
  • Annual vs. quarterly provision: Howard Telson / CrossBorder Solutions→
    March 23, 2022

Transfer Pricing News

  • New CbC Reporting Requirements to Apply in Kenya
    July 7, 2022
  • The Evolution of Transfer Pricing in Saudi Arabia
    June 23, 2022
  • The Functional Analysis—What You Need to Know
    June 22, 2022
  • How International Organizations are Changing Transfer Pricing Compliance
    June 22, 2022
  • The OECD’s Tax Transparency in Africa 2022: Africa Initiative Progress Report
    June 22, 2022

US tax focus

  • Policy Paper: Transfer pricing documentation
    July 26, 2022
  • Indonesia Taxes Crypto Asset Transactions
    July 12, 2022
  • New CbC Reporting Requirements to Apply in Kenya
    July 7, 2022
  • The Colombian National Tax and Customs Administration (DIAN) modified 2021’s Resolution 164 related to the Ultimate Beneficial Owner´s Report (RUB).
    July 5, 2022
  • Frustrated with Congress, Intel delays chips groundbreaking ceremony
    June 28, 2022

Trending Now

  • Arm’s length principle mutations: control of risk in the OECD guidelines and variations in practice by Andrew Hickman | posted on January 13, 2021
  • OECD officials note disagreement over digital tax update, reveal plans for tax and transfer pricing guidance by Julie Martin | posted on May 4, 2020
  • US Tax Court resolves Whirlpool tax dispute involving Mexican maquiladora structure by Elisa Kaminsky | posted on May 13, 2020
  • Indian court stays controversial Mastercard tax decision on permanent establishment by Staff | posted on October 29, 2018
  • Nike’s transfer pricing state aid dispute: the underlying issues by Dr. Harold McClure | posted on July 19, 2021
  • How prudent is it to conduct transfer pricing risk adjustments for captive cost centres? by Smarak Swain | posted on May 4, 2021
  • Return on assets (ROA) is an unreliable profit indicator by Ednaldo Silva | posted on October 2, 2019
  • AgraCity’s Canada transfer pricing dispute: co-distribution and the markup for logistics by Dr. Harold McClure | posted on September 2, 2020

International Tax News
Transfer Pricing News

Publish with MNE Tax

About

Contact Us

Privacy Policy

Cookie Policy

Stay connected
  • LinkedIn
  • Twitter
  • Facebook

Copyright © 2021. DISCLAIMER: The information provided herein is general and may not be applicable in all situations. It should not be acted upon without legal advice accounting for a particular situation.