Transfer Pricing Case Laws
OECD releases new 2022 edition of the OECD Transfer Pricing Guidelines
Today, the OECD releases the 2022 edition of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations. The OECD Transfer Pricing Guidelines provide guidance on the application of ...
Finnish TP-Legislation updated to include non-recognition and recharacterisation
Effective as of 1. January 2022 Finnish Transfer Pricing legislation has been updated to align the rules with the OECD Transfer Pricing Guidelines in regards to non-recognition and recharacterisation. Going ...
EU directive on minimum effective tax rate – implementation of OECD Pillar II
The European Commission has proposed a Directive ensuring a minimum effective tax rate for the global activities of large multinational groups. The proposal delivers on the EU’s pledge to move ...
OECD releases Pillar Two model rules – Global Minimum Tax of 15%
The OECD has published detailed rules to assist in the implementation of a landmark reform to the international tax system, which will ensure Multinational Enterprises (MNEs) will be subject to ...
ResMed Inc has entered a $381.7 million tax settlement agreement with the Australian Tax Office
ResMed – a world-leading digital health company – in an October 2021 publication of results for the first quarter of FY 2022, informs that a $381.7 million tax settlement agreement ...
Amgen in $3.6 billion transfer pricing dispute with the IRS
Amgen, in a note to its financial statement for the quarterly period ended June 30, 2021, disclosed that it has been issued tax assessments of approximately $3.6b plus interest for ...
Pandora Papers – a new leak of financial records
A new huge leak of financial records revealed by ICIJ, once again shows widespread use of offshore accounts, shell companies and trusts to hide wealth and/or avoid taxes. The new ...
OECD deal on taxation of MNEs – Global Minimum Tax of 15%
Major reform of the international tax system finalised today at the OECD will ensure that Multinational Enterprises (MNEs) will be subject to a minimum 15% tax rate from 2023. The ...