MNE Tax

invocation pour avoir de l'argent en islam

C'est enfin des rituels complexes par lesquels vous ai et moi pouvons pactiser avec les dmons pour qu'ils nous enrichissent. (Mouslim). La volont de La notion de Bid'a en Islam. This cookie is set by ...
MNE Tax

Danish High Court rules on the application of EU Arbitration Convention and MAP in transfer pricing case

On September 9, 2021, the High Court of Eastern Denmark ruled in a remarkable transfer pricing case on the application of the EU Arbitration Convention and mutual agreement procedures. The High Court ...
MNE Tax

Barbados country-by-country reporting tax law takes effect

Barbados tax legislation enacting country-by-country reporting came into operation on December 31, 2021, following publication in the Official Gazette on December 24. The new reporting requirement ...
MNE Tax

Italy tax agency issues circular on transfer pricing documentation rules

On 26 November, the Italian revenue agency finally issued the Circular (Circular No. 15/E) aimed at providing clarifications and increasing the level of certainty on the interpretation of new ...
MNE Tax

Whirlpool profits routed through foreign subsidiary subject to US tax, court holds

The US Court of Appeals for the Sixth Circuit in a December 6 decision held that Whirlpool must pay taxes on more than USD 45 million in profits for which the appliance manufacturer had evaded paying ...
MNE Tax

Zambian budget 2022 includes corporate income tax, transfer pricing changes

The Zambia Revenue Authority on November 5 published an overview of tax measures in the Minister of Finance’s 2022 budget address delivered on October 29, including changes to the corporate income tax ...
MNE Tax

Australian Taxation Office’s transfer pricing audit of ResMed: an illustrative model

Medical equipment company ResMed has reached a settlement with the Australian Tax Office (ATO) for USD 381.7 million in additional taxes in connection with an ATO audit over certain transfer pricing ...
MNE Tax

Australia updates guideline on simplified transfer pricing record-keeping options

The Australian Taxation Office on November 11 amended its practical compliance guideline on simplified transfer pricing record-keeping options to provide maximum and minimum interest rates for ...
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

E-invoicing and interaction with transfer pricing: a Middle East and African perspective

Every business in carrying out its day-to-day operations issues and receives thousands of invoices for purchase and sale of goods. An invoice is a time-stamped commercial document that itemizes and ...
MNE Tax

Germany updates tax dispute resolution and mutual agreement procedures

Germany’s Federal Ministry of Finance published on 27 August updated guidance on international dispute resolution, replacing the existing guidance dated 9 October 2018. For the first time, the new ...
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 ...