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 ...

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 ...

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. Harold McClure, a New York City economist, discusses how recently revised accounting standards for entities with leased assets impact the financial metrics often used in transfer pricing . . .

Dr. Ednaldo Silva, Founder & Director at RoyaltyStat, discusses whether transfer pricing analysis of operating profits should be based on EBITDA or EBIT . . .

Jian-Cheng Ku and Mehdi el Manouzi, DLA Piper Nederland N.V., Amsterdam, discuss August 27 Netherlands Ministry of Finance guidance describing the new Dutch policy with respect to the tax treatment of ...

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 ...

Nour Ali, DNV, discusses Morocco's Mutual Agreement Procedure (MAP) guide, released July 5 through the General Tax Administration of the Ministry of Economy and Finance, for resolving tax disputes not ...

The Australian Taxation Office (ATO) and an Australian affiliate of US aluminum giant, Alcoa, are locked in a transfer pricing dispute over the price the affiliate charged a related Bahrain company ...

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 ...

Gabriel Nwodo and Oluwapelumi Omoniyi of AELEX, Nigeria, discuss a new Nigerian order addressing when a digital business operated by a nonresident company is deemed to have a significant economic ...

Susi Baerentzen, Carlsberg Foundation Postdoctoral Fellow, discusses the Danish parliament's June 3 passage of a bill to adopt changes to the controlled foreign corporation (CFC) regime necessary for ...