Late 2021, Finland implemented a regulation concerning taxation of reverse hybrid arrangements included in article 9a of ATAD2 directive (Council directive (EU) 2017/952 amending Directive 2016/1164).

The tax regimes of the six countries—the Kingdom of Saudi Arabia, the Kingdom of Bahrain, the State of Kuwait, the Sultanate of Oman, the State of Qatar and the United Arab Emirates—that make up the ...

Stay up to date on the latest tax and transfer pricing news with our free newsletter Sign Up Now Sign Up Now ...

The Biden Administration recently released its fiscal year 2023 budget, which included additional reforms to the tax treatment of multinational corporations. These reforms are meant to further align ...

Australia’s transfer pricing rules apply the arm’s length principle to dealings between both associated and non-associated entities so that any non-arm’s length dealings should reflect the economic ...

During the last decade, the Belgian tax authority has consistently ramped up its transfer pricing audit capacity and frequency. Audits are carried out by both a dedicated transfer pricing cell within ...

The French Court of Appeal decided in favor of the multinational in a somewhat involved intercompany financing pricing issue in a January 25 decision denoted as case number 20VE00792. SAS Electricité ...

Practitioners were confronted with a plethora of updates to the relevant regulations and administrative principles throughout 2020 and 2021. From the perspective of MNEs with operations in Germany, ...

Throughout the first year of the Biden administration, one tax policy theme was consistent. The President and Treasury Secretary Janet Yellen were focused on increasing the tax burden on U.S.

Applying a domestic anti-avoidance rule, the Court of Appeal of Trinidad and Tobago has decided that a Trinidad subsidiary’s dividend payments to a holding company in Barbados were liable to ...

EU member states are at odds on various issues in connection with the directive to implement within the EU the global minimum tax portion of the OECD agreement, with several members expressing ...

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 ...