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

The Colombian National Tax and Customs Administration (DIAN) modified 2021’s Resolution 164 related to the Ultimate Beneficial Owner´s Report (RUB).

According to Resolution 37 from March 17, 2022, DIAN modified articles 4, 10, and 13 of 2021’s Resolution 164, which provided administrative regulation to articles 631-5 and 631-6 of the Colombian ...
MNE Tax

Mexico’s 2022 income tax law takes effect, incorporates notable transfer pricing changes

In January, Mexico’s 2022 income tax law went into effect. It incorporates several changes the Mexican legislature proposed in September 2021, including various changes in transfer pricing. The ...
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

Taiwan tax agency clarifies R&D tax credit eligible expenses

Taiwan’s National Taxation Bureau on November 11 stated that not all expenditures resulting from research and development (R&D) departments can be declared for tax credits even when companies are ...
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

Australia plans to add 10 new tax treaties in next two years

Australia plans to expand its existing network of 45 bilateral tax treaties by entering into 10 new and updated tax treaties by 2023, according to a September 15 announcement from Australian Treasurer ...
MNE Tax

Spain tightens international tax transparency rules and introduces concept of ‘non-cooperative jurisdictions’

Spain published on July 9 a law to prevent and combat tax fraud (Law 11/2021), triggering changes to various tax concepts and to the general taxation law itself. Provisions in the anti-fraud law ...