European Commission vs Apple and Ireland (Appeal)
The CJEU's judgment of 10 September 2024 overturned the General Court's previous ruling, confirming that Ireland's tax rulings to Apple Sales Internat…
What is Comparability Analysis in Transfer Pricing?
Comparability Analysis in Transfer Pricing is a cornerstone of ensuring that transactions between related parties in multinational enterprises (MNEs) …
Understanding the Role of Permanent Establishments in Transfer Pricing
Permanent Establishments (PEs) play a crucial role in the realm of transfer pricing, as they serve as the bridge between international taxation and mu…
General Court Judgment in Amazon and Luxembourg v European Commission
The General Court of the European Union ruled in favour of Luxembourg and Amazon, annulling the European Commission's decision that Luxembourg granted…
Tax Planning in International Taxation: Navigating Compliance and Avoidance
International Tax Planning is a crucial aspect for multinational corporations seeking to optimize their global tax obligations. With the increasing co…
Understanding Double Tax Treaties: A Comprehensive Guide
*For clarity, the term Double Tax Treaty (DTT) used in this article has the same meaning as Double Tax Agreement (DTA). Double Tax Treaties (DTTs)
Mutual Agreement Procedures (MAP): Key Guidelines
Mutual Agreement Procedures (MAP) are key mechanisms that ensure fair tax treatment in international transactions. They help resolve conflicts between…
Effective Transfer Pricing Dispute Resolution
As global trade increases, so does the complexity of transfer pricing arrangements, leading to potential disputes between multinationals and tax autho…
The Critical Role of Business Restructuring in Transfer Pricing
Business restructuring in transfer pricing is a critical topic for multinationals, tax professionals, and revenue services. It involves significant changes in a company’s structure, operations,
Exactera’s 2024 TP Symposium
I am pleased to announce that I will be speaking at the upcoming 2024 TP Symposium in Lausanne, Switzerland, on September 17-18. My presentation will …