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Francesca Amaddeo, a Researcher at the Tax Law Competence Centre (SUPSI), Manno, Switzerland writes about the Platform for Collaboration on Tax's June 4 toolkit on taxation of offshore indirect ...

Noopur Trivedi and Jitesh Golani, international tax researchers, discuss how – out of the multiple design elements of the global minimum tax in the OECD/G20 July 1 statement – the adoption of ...

This article examines the application of the arm’s length principle in the context of a related-party transaction that is characterized by integrated collaboration among decentralized business units ...

International tax researchers Noopur Trivedi and Jitesh Golani discuss key highlights of the OECD's much-awaited global anti-base erosion (GloBE) model rules, released on December 20, along with a ...

Daniel Bunn, Tax Foundation, discusses why a meaningful tax hike for multinational companies has already been adopted while much of the policy focus has been on proposals embedded in the Build Back ...

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 ...

Geoff Morris, InTP, provides an overview of Australia’s transfer pricing laws and the tax administration’s practices in this area, focusing on the provisions, as well as on how Australia monitors ...

Allan Lanthier, a former advisor to the Canadian government, analyzes the recent treaty shopping decision of Trinidad and Tobago's Court of Appeal – a decision that stands in stark contrast to the ...

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 ...

Aitor Navarro, Carlos III University, discusses the September 22 Spanish Supreme Court decision regarding SGL Carbon Holding (ECLI:ES:TS:2021:3572), addressing the denial of a mutual agreement ...

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 ...