MNE Tax

high school baseball bat rules 2022

Demarini has been known for its high-performing aluminum bats for several years, and this model is no different. Wood bats allowed. The KHSAA Board of Control has approved the RPI to be used as a ...
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

Catherine Harlow is new head of transfer pricing at AstraZeneca

Catherine Harlow is AstraZeneca’s new head of transfer pricing, taking on her new role earlier this month. Harlow, a frequent speaker at TP Minds and other transfer pricing conferences, joins the ...
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 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

The Pillar One blueprint — the potential future of international taxation and transfer pricing

Following a meeting of the OECD’s Inclusive Framework members, the OECD on 12 October released its Pillar One and Pillar Two ‘blueprints’, which reflect significant proposals to reform the ...
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 rules on beneficial ownership of dividends for tax purposes

On May 3, the High Court of Eastern Denmark ruled in two of the most famous tax cases in modern times: the beneficial ownership cases. These two domestic rulings, the TDC case known as C-116/16 T ...
MNE Tax

The Puma Nordic and Columbia Sportswear transfer pricing cases and the limits of the TNMM

In their February 11 MNE Tax article, Erik Koponen and Madeleine Thörning analyze a successful challenge by the Swedish tax agency with respect to the transfer pricing between Puma SE and its Swedish ...
MNE Tax

Jordan publishes executive instructions for transfer pricing rules

On 16 September, Jordan provided further implementation instructions relating to the transfer pricing rules through executive instructions No. 3 of 2021. The executive instructions shall apply with ...
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 ...