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 pricingTransfer pricing is a fundamental concept in international taxationFOR MORE INSIGHT ON INTERNATIONAL TAXATION, PLEASE READ THIS ARTICLE: Introduction to International Taxation: Key Concepts & Guidelines International Taxation encompasses the framework of laws, principles, and treaties that govern the tax obligations of individuals and entities engaged in economic activities that span multiple jurisdictions. This field addresses how income, profits, and gains are taxed when operations or investments extend... that defines the pricing methods and rules applied to transactions between related
How Changes in Tax Residency Impact South African Trusts
The impact of tax residency on South African trusts introduces several complexities that require meticulous planning. This guide explores the critical…
The Second Session of the Ad Hoc Committee on the UN Tax Convention
The Second Session of the Ad Hoc Committee on the UN Tax Convention, held from July 29 to August 16, 2024, at the UN Headquarters in New York, was a s…
13th Annual SAIT Transfer Pricing Summit 2024: Key Topics and Insights
The 13th SAIT (South African Institute for Taxation) Transfer Pricing Summit 2024 is set to be a pivotal event for tax professionals and policymaker…
What is a Permanent Establishment, and How is Its Significance in Transfer Pricing?
A Permanent Establishment (PE) refers to a fixed place of business through which a foreign enterprise conducts business in another country. In the con…
The Italian Supreme Court’s Landmark Ruling on Loss-Making Entities: My Take
In August 2024, the Italian Supreme Court delivered a pivotal ruling on transfer pricing, specifically addressing the inclusion of loss-making entitie…
The OECD’s Transfer Pricing Framework for Mineral Pricing
Transfer pricing in the mineral sector is a complex yet crucial aspect of international tax compliance. The OECD has developed a comprehensive framewo…
Italian Supreme Court Ruling on Transfer Pricing: Inclusion of Loss-Making Entities in Comparability Analyses
The Italian Supreme Court's 2024 ruling mandates including loss-making entities in transfer pricing comparability analysis, aligning with OECD guideli…
Transfer Pricing and Profit Attribution to Permanent Establishments: Insights from Recent Cases
In the increasingly complex landscape of international taxation, Transfer Pricing and Profit Attribution to Permanent Establishments (PEs) have emerge…