International Tax Report

Anas Salhieh analyses the detail of the MAP guidance issued by the General Authority for Zakat and Tax in response to OECD peer review recommendations.In a peer review report published on 28 November 2019,1 the OECD recommended that the Kingdom of..

KPMG in the UK summarises recent corporate tax developments of potential interest to ITR readers.BEPS 2.0 – Pillar one and Pillar two blueprintsThe BEPS 2.0 Pillar 1 and Pillar 2 Blueprints have been released by the OECD’s Inclusive Framework and..

Adetayo Adetuyi and Nnanke Williams explore the detail of Nigeria’s first transfer pricing related judgment, in Prime Plastichem Nigeria Ltd v Federal Inland Revenue Service.Earlier this year, the first judgment relating to transfer pricing in..

Two recent transfer pricing appeals in the Tax Court of Canada underline the principles of law set out in the watershed Cameco judgment. Larry Nevsky and Mark H Woltersdorf present the facts and some of the key points held.The Agracity Ltd and..

The Canadian appeals court has issued a landmark judgment on “non-recognition” transfer pricing rules. Alexander Demner provides some commentary on the dispute and the court’s findings.On 26 June 2020, the Canadian Federal Court of Appeal (FCA)..

Malta’s Office for the Commissioner of Revenue has issued guidelines for the Anti-Tax Avoidance Directives (ATADs) Implementation Regulations.1 The aim of the guidelines is to steer businesses and other organisations through the application of the..

Michael Alexandrou presents some recent legislative developments – including the adoption of the controlled foreign company, interest limitation and hybrid mismatch rules under the Anti-Tax Avoidance Directive – which challenge perceptions of Cyprus..