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By Francesca Amaddeo, Researcher, Tax Law Competence Centre (SUPSI), Manno, Switzerland On 4 June, the Platform for Collaboration on Tax, a joint initiative of the IMF, OECD, UN, and World Bank Group ...

By Noopur Trivedi and Jitesh Golani 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” ...

By Oliver Treidler, Tom-Eric Kunz, Maximilian Capraro, and Michael Dorner [1] Most contemporary developments in transfer pricing relate to intangibles. Appropriately coping with increasingly highly ...

By Noopur Trivedi and Jitesh Golani Today, the OECD released the much-awaited global anti-base erosion (GloBE) model rules with a commitment to finalize the commentary and safe harbors in early 2022.

By Daniel Bunn, Vice President of Global Projects, Tax Foundation, Washington, D.C. Throughout the first year of the Biden administration, one tax policy theme was consistent. The President and ...

by Julie Martin 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 ...

By Geoff Morris, Transfer Pricing Advisor, Director, Independent Transfer Pricing (InTP), Melbourne, Australia Australia is one of the Group of Twenty nations that delivers internationally-coordinated ...

By Allan Lanthier, Montreal, retired partner of an international accounting firm and former advisor to the government of Canada Applying a domestic anti-avoidance rule, the Court of Appeal of Trinidad ...

By Giuliana Polacco & Annarita De Carne, Studio Legale Bird & Bird, Milan The Italian Revenue Agency, on March 23, issued long-awaited guidance clarifying the application and implementation of the ...

By Aitor Navarro, Assistant Professor, Carlos III University, Madrid The Spanish Supreme Court, in the case of SGL Carbon Holding (ECLI:ES:TS:2021:3572) issued September 22, addressed the denial of a ...

By Vasiliki Koukoulioti, Lecturer in Law at Newcastle University, Newcastle upon Tyne, England In its judgment of March 23 in Commissioners for Her Majesty’s Revenue and Customs v NCL Investments Ltd ...