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

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

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

The US and Mexico’s transfer pricing approach for maquiladoras

The US and Mexico have agreed to renew their transfer pricing framework for US multinational enterprises that have maquiladora operations, according to a November 16 IRS announcement. The 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

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

US IRS prevails in Coca-Cola transfer pricing dispute over intercompany royalties

The US Tax Court ruled on November 18 that Coca-Cola’s US-based income should be increased by about $9 billion in a dispute over the appropriate royalties owned by its foreign-based licensees for the ...
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

Turkey proposes 7.5 percent digital services tax on large multinationals

Turkey’s Ministry of Treasury and Finance on 23 October released a draft law introducing a digital services tax, sending it to the Turkish Parliament for ratification. Turkey’s digital services tax is ...
MNE Tax

The Pillar One blueprint — the potential future of international taxation and transfer pricing

Following a meeting of the OECD’s Inclusive Framework members, the OECD on 12 October released its Pillar One and Pillar Two ‘blueprints’, which reflect significant proposals to reform the ...
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

“Synthesized text” of UK-Slovenia tax treaty reflects MLI changes

The UK government today released the synthesized text of the 2007 UK-Slovenia tax treaty, prepared jointly by the competent authorities of the UK and Slovenia, which reflects how the countries believe ...