Whilst some countries have had comprehensive rules on controlled foreign corporations for years, Luxembourg only introduced such rules...

The articles discusses the developments with respect to the digital economy and what it will mean for the international tax practice. The...

ATAF has published  policy brief for Digital service taxation to assist the ATAF members in their tax policy considerations of the...

Advance Pricing Agreements (APAs) are a diffused tool for taxpayers to obtain certainty in relation to the tax impact of their...

The Global Tax Controversy (GTC) team is a leading platform for sharing knowledge and experience in the area of international tax...

The OECD reached another milestone recently in connection with its base erosion and profit shifting project when it released the first...

Recognizing  the need to bring greater clarity, objectivity, and predictability in the matter of attribution of profit to a Permanent...

The potential of globalization and digitization is clearly shown in international taxation which is in the phase of complete overhaul....

Article 26 of Legislative Decree No. 78/2010 introduced in Italy a rewarding regime related to the non-application of penalties involving...

Rulings on transfer pricing matters issued in the last few years by Italian Courts covered various themes. Among these, the Tax...