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

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

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

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

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

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 ...
MNE Tax

Morocco publishes mutual agreement procedure guide for resolving tax disputes

On 5 July, the Kingdom of Morocco (Morocco) officially issued the Mutual Agreement Procedure (MAP) guide through the General Tax Administration of the Ministry of Economy and Finance. The purpose of ...
MNE Tax

Indian court rules most favored nation clause triggered in tax treaty with Netherlands

The High Court of Delhi on 22 April ruled in a landmark judgment that the dividend income earned by a resident of the Netherlands from an Indian company is taxable at 5%, rather than at 10%, as is ...
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

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 ...