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 ...

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

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 ...

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 ...

Rubeena Dina, Director at GTS Africa – Mauritius, discusses a Rwandan government ministerial order establishing general rules on transfer pricing . . .

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 ...

Amanda Varma and Brigid Kelly of Steptoe & Johnson LLP, Washington, discuss the international tax provisions in the Tax Cuts and Jobs Act of 2017, including the new dividend-exemption system, the ...

Rubeena Dina and Aniruddha Saha, GTS Africa, discuss the global trend of tax authorities' introducing electronic invoicing requirements and the implications for transfer pricing in the Middle East and ...

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 ...

Dr. Harold McClure, a New York economist, discusses transfer pricing issues with respect to Whirlpool's Mexico affiliate, which conducted toll manufacturing operations on behalf of a Luxembourg ...

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 ...