Transfer Pricing

Transfer pricing adjustments under Article 9 of the model treaties are the most common form of dispute that is dealt with under the mutual agreement procedure. It is for this reason that the OECD…

"When I use a word," Humpty Dumpty said in rather a scornful tone, " it means just what I choose it to mean, neither more nor less." (Lewis Carroll, Alice through the Looking Glass) Prior to the OECD…

Coca-Cola announced that it would appeal to the Eleventh Circuit Court of Appeals, based in Atlanta, the Tax Court’s final entered decision of August 2, 2024, in favor of the IRS’ determination of $9…

On Friday, the U.S. Supreme Court issued its expected overruling of the Chevron doctrine, which has been relied upon in 70 past Supreme Court decisions and approximately 17,000 in the Appellate and…

The opinion of AG Emiliou in X BV v. the Dutch Ministry of Finance (C-585/22) Dr. Svitlana Buriak (Loyens & Loeff / University of Amsterdam)[1]   Can a transaction entered into between two associated…

Introduction The present contribution aims at discussing two fundamental concepts often coming into play in the analysis of transactions between associated enterprises involving intangible property:…

Back in 2015, my first ever blog asked Does the UK Diverted Profits Tax help or hurt BEPS? Whatever the answer, the level of complexity and the challenges it brought to UK cross-border taxation…

We are happy to inform you that the latest issue of the journal is now available and includes the following contributions: Tsilly Dagan, GLoBE: The Potential Costs of Cooperation This article argues…

We are happy to inform you that the latest issue of the journal is now available and includes the following contributions: Jeroen Lammers & Błażej Kuźniacki, The EU Solidarity Contribution and a More…