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

Transfer Pricing

Featured News

OECD “MLI Matching Database” for tax treaties goes live

July 10, 2017

The OECD made public its “MLI Matching Database” for tax treaties in beta this week. The database will assist in determining whether an in-force tax treaty . . .

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 . . .

Europe

Russian draft law on country-by-country reporting introduced: DLA Piper→

May 5, 2017
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. . . 

Europe

Ireland’s legal arguments in Apple State aid tax case published

February 6, 2017

Mary Cosgrove, a tax lecturer at the J. E. Cairnes School of Business & Economics at the National University of Ireland, discusses Ireland’s arguments in the Apple State aid case before the Court of Justice of the European Union, as revealed in the government’s summary of  legal proceedings, released today . . . .

Europe

UK to reject EU Commission CCCTB plan: The Guardian→

October 21, 2016

See: The Guardian.

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.

Europe

UK to extend country-by-country tax reporting to partnerships

August 2, 2016

The UK’s HM Revenue and Customs today announced that it will propose amendments to existing country-by-country reporting regulations applicable to large multinational enterprises to add . . .

Asia-Pacific

Australian guidance details procedure when transfer pricing adjustments affect customs values

April 15, 2016

The Australian government has released details on the how the tax office (ATO) will respond to taxpayer requests for help determining customs duty values following a . . .

Europe

UK Public Accounts Committee concludes it’s impossible to tell if £130 million Google tax settlement was fair: UK Parliament→

February 24, 2016

See: UK Parliament.

No Picture
Europe

Switzerland to sign BEPS country-by-country reporting multilateral agreement

January 20, 2016

Swiss tax officials intend to sign next week a multilateral agreement to implement country-by-country reporting developed under the OECD/G20 base erosion profit shifting (BEPS) plan, Switzerland’s Federal . . .

Asia-Pacific

BHP Billiton to appeal High Court in tax dispute involving Singapore marketing hub: Tom McIlroy / Financial Review→

March 13, 2019
No Picture
Europe

Chris Whitehouse joins Questro International’s Zurich office

February 7, 2019

Chris Whitehouse, a transfer pricing specialist with over 19 years of experience, has . . .

Asia-Pacific

Indian court stays controversial Mastercard tax decision on permanent establishment

October 29, 2018

An Indian appellate court has stayed the Authority for Advance Rulings (AAR) decision in Mastercard, which adopted an expansive view of when a multinational group’s activities in India create a taxable permanent establishment . . .

Asia-Pacific

Australia, France, Japan, Slovak Republic ratifiy BEPS MLI

September 27, 2018

Australia, France, Japan, and the Slovak Republic have ratified a multilateral tax treaty designed to swiftly add to their existing tax treaties . . .

Featured News

OECD publishes 78 comments on transfer pricing guidelines for financial transactions

September 17, 2018

The OECD on Friday published comments written in response to its July 3 discussion draft on proposed transfer pricing rules for intragroup financial transactions. Altogether . . .

Americas

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

August 18, 2018
Europe

Ukraine signs BEPS MLI to counter tax avoidance by multinationals

July 23, 2018

Ukraine today became the 83rd jurisdiction to sign a multilateral tax treaty designed to swiftly amend bilateral tax treaties to add new provisions countering tax avoidance by multinationals and easing the resolution . . .

Featured News

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

May 22, 2018

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 in New York. The new treaty and commentary update the UN’s . . .

Asia-Pacific

Bahrain joins the “Inclusive Framework on BEPS,” commits to fight tax avoidance

May 15, 2018

Bahrain has joined the “Inclusive Framework on BEPS,” a group of now 115 countries that have pledged to adopt minimum standards developed by OECD and G20 countries in the 2015 base erosion profit shifting (BEPS) plan agreements, the OECD . . .

Asia-Pacific

Australian tax authority challenging Exxon subsidiary’s intercompany loan interest deductions: Peter Ker / Financial Review→

April 27, 2018
Asia-Pacific

Pakistan publishes amendments to country-by-country reporting scheme

January 31, 2018

Pakistan’s Federal Board of Revenue on January 31 published amendments to draft rules that establish transfer pricing documentation and country-by-country reporting obligations on large . . .

Featured News

Peer review of OECD and G20 countries shows mixed progress on exchange of private tax ruling information

December 4, 2017

The OECD today released peer reviews assessing whether 44 countries have met their commitments to disclose information to other countries about the private tax rulings they grant to multinational firms. The commitments, made as a part of 2015 OECD/G20 base erosion profit shifting (BEPS) plan agreements between . . .

Featured News

UN handbook on tax avoidance includes new chapters on rents, royalties, GAAR

September 11, 2017

The UN has published the second edition of the United Nations Handbook on Selected Issues in Protecting the Tax Base of Developing Countries, updating the manual and adding new chapters on base-eroding payments of rents . . .

Africa

Transfer pricing comparables “toolkit” reflects realities of developing nations, UN official says

July 20, 2017

A new “toolkit” which considers how developing nations can address a lack of comparables in transfer pricing, released jointly by the UN, OECD, IMF, and World Bank Group last June, reaffirms that the arm’s length approach can work for all nations but is also an imperfect, “not scientifically pure,” document, a UN official said July 18.  Michael Lennard . . .

Asia-Pacific

Australia: tax guidance on cross-border related party financing released

May 16, 2017

The Australian Taxation Office on May 16 issued draft guidelines on cross-border related party financing arrangements. In the . . .

Europe

Luxembourg tax guidance addresses intragroup financing, updates ruling procedure

January 3, 2017

The Luxembourg government on December 27 published new tax guidance for intragroup financing transactions. The guidance . . . 

Americas

Amici Curiae brief of 6 law professors in Altera case available; profs argue IRS stock-based compensation cost sharing regs are valid: SSRN→

August 17, 2016

See: SSRN.

Americas

US and OECD transfer pricing guidance compared: Robert T. Cole, William Byrnes / SSRN→

August 2, 2016

See: Practical Guide to U.S. Transfer Pricing § 2.01 – § 2.19, SSRN.

Multinational

OECD guidance on allocation of profit to PEs to address interaction with transfer pricing: Alex M. Parker / Bloomberg BNA→

June 18, 2016

See:  Bloomberg BNA.

No Picture
Europe

More tax rulings under EU scrutiny for illegal state aid, Vestager says

April 5, 2016

The European Commission is scrutinizing advance pricing agreements (APAs) issued to financing companies and to other businesses for potential state aid violations EU competition commissioner Margrethe . . .

No Picture
Europe

EU to require country-by-country tax reporting, limited public release of data likely

March 8, 2016

European Union finance ministers today reached political agreement on requiring EU-wide country-by-country reporting by multinational corporations and on sharing that data between tax administrations. It was also revealed today that any future. . .

Featured News

The UN transfer pricing manual’s new chapter on financial transactions: the details

April 15, 2019

Pilar Barriguete and Edland Graci of Duff & Phelps, Spain, offer a detailed analysis of the UN Committee of Experts on International Cooperation in Tax Matters’ April 8 a draft chapter on financial transactions, proposed as an update to the UN Practical Manual on Transfer Pricing for Developing Countries . . .

Africa

Egypt to adopt ‘revolutionary’ tax changes by 2020, will implement transfer pricing rules, finance minister says: Hagar Omran / Daily News Egypt→

December 18, 2018
Africa

OECD officials discuss international tax and transfer pricing agenda

October 16, 2018

Tax officials provided an update on international tax and transfer pricing work underway at the OECD Centre for Tax Policy and Administration during an OECD Tax Talks webinar, held October 16. This latest webinar covered a range of topics, including OECD efforts to facilitate global agreement on . . .

Americas

US IRS issues new transfer pricing examination guide

July 6, 2018

The US IRS on June 29 issued the new guidelines on best practices in transfer pricing examinations, retiring the 2014 Transfer Pricing Audit . . .

No Picture
Europe

Swiss to exchange first country-by-country tax reports on multinationals

June 18, 2018

The Swiss government today announced that, by the end of June, the Federal Tax Administration (FTA) will send its first country-by-country reports on multinational . . .

Asia-Pacific

Transfer pricing specialist Joel Phillips joins BDO Australia

June 7, 2018

Transfer pricing specialist, Joel Phillips, has joined BDO as a partner in its Sydney office, the . . .

No Picture
Europe

EU Commission publishes 121 comment letters on taxation of digital economy, hosts roundtable discussions with stakeholders

March 7, 2018

The EU Commission has published the results of its questionnaire on the taxation of the digital economy along with 121 comment letters responding to its consultation on this issue. Eighty-two percent of the 416 questionnaire respondents . . .

Posts navigation

« 1 … 24 25 26 … 43 »

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

  • 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
  • Arm’s length principle mutations: control of risk in the OECD guidelines and variations in practice by Andrew Hickman | posted on January 13, 2021
  • 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
  • OECD lists countries agreeing to country-by-country reporting exchange by Staff | posted on May 4, 2017
  • Return on assets (ROA) is an unreliable profit indicator by Ednaldo Silva | posted on October 2, 2019
  • The economics of leasing and the arm’s length standard by Dr. Harold McClure | posted on October 9, 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.