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

“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 ...
MNE Tax

Nigeria international tax and transfer pricing expert authors

Gabriel Nwodo is an Associate in the Lagos offices of ǼLEX. He is a member of the Tax, Corporate/Commercial, and Dispute Resolution practice groups of the firm. Gabriel routinely assists local and ...
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

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

Nigeria clarifies new tax on nonresident digital businesses

On 29 May, Nigeria’s Minister of Finance issued an order describing when a digital business operated by a nonresident company is deemed to have a significant economic presence in Nigeria and is thus ...
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 economics of leasing and the arm’s length standard

On September 23, the EU General Court ruled that the Spanish tax lease system constitutes illegal state aid, in a case often referred to as the Lico Leasing case. The Spanish tax lease system is a ...
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

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

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 ...
MNE Tax

The revised operating lease accounting standards: what are the implications for transfer pricing?

Recently revised accounting standards issued by the International Accounting Standards Board and the Financial Accounting Standards Board impact the income statement and balance sheets for entities ...