MNE Tax

dr bronner's sugar soap vs castile soap

I prefer the sugar wash since I dont have to dilute it and it comes with a pump for easier application. All of Dr. Bronners products are certified all-natural, vegan, cruelty-free, GMO-free, fair ...
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

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

The UN transfer pricing manual’s guidance on intercompany interest rates in the extractive sector

The UN, on April 27, released a new edition of the United Nations Practical Manual on Transfer Pricing for Developing Countries, including its latest chapter on transfer pricing for the extractive ...
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

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

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

Irish budget changes: some implications for MNEs

Ireland’s budget released today introduces two changes that have implications for MNEs, namely, a knowledge development box (KDB) and a requirement for country-by-country reporting. The KDB, first ...
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

GloBE model rules: a peek into key provisions

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. The rules are segmented into ten ...
MNE Tax

Netherlands announces changes to tax treatment of Brazil interest on equity payments

On August 27, the Netherlands Ministry of Finance published guidance describing the new Dutch policy with respect to the tax treatment of interest on equity payments under the Netherlands-Brazil tax ...
MNE Tax

Paraguay clarifies transfer pricing rules

The executive branch of Paraguay has issued further regulations on the transfer pricing rules established in Law No. 6,380/2019 through Decree No. 6,105/2021, released October 14, and General ...