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12 articles found

Exchange of information on reportable cross-border tax arrangements: CJEU Judgment in Case…

The judgment in the case C-623/22, issued by the Court of Justice of the European Union (CJEU) on July 29, 2024, primarily addressed the…

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Luxembourg vs “LLC AB”: Luxembourg Court Upholds Debt Classification of Interest-Free Loan in…

Luxembourg court rules interest-free loan qualifies as debt, allowing notional interest deduction in landmark transfer pricing case with…

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Transfer Pricing Case: Czech Republic vs. AHI Oscar S.R.O.

Explore the in-depth analysis of the landmark transfer pricing case between Czech Republic and AHI Oscar S.R.O., highlighting its…

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In-depth Analysis of Ireland’s First Transfer Pricing Case

Discover the critical insights from Ireland’s first transfer pricing case, impacting multinationals and tax authorities worldwide. Learn…

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Analysis of BlackRock HoldCo 5, LLC v HMRC: Transfer Pricing and Unallowable Purpose Test

Explore the key aspects and implications of the BlackRock HoldCo 5, LLC v HMRC case, focusing on transfer pricing and the unallowable…

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The Journey of a Single Data Point: Cross-Process TP Automation in Workiva

As Tax/TP practitioners, we are always looking to build synergies across processes, harmonizing our calculation and reporting flows. Aiming…

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FREE Online Workshop: Conducting a Transfer Pricing Trial

Learn how to best Conduct a Transfer Pricing Trial with leading experts Prof. Dr. Daniel N Erasmus and Mr. Renier van Rensburg from…

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EU Tax Law

Dr. Erasmus, with his expertise in tax law, can provide valuable guidance on navigating the complexities of EU tax regulations, helping…

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International Taxation of E-commerce Business Income

Article by: Dr. Dennis Ndonga (Lecturer, Murdoch University Australia) The rapid growth of cross-border e-commerce has challenged the…

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Double Tax Treaties: An Introduction

Paper by: Reuven S. Avi-Yonah The existing network of over 2,500 bilateral double tax treaties (DTTs) represents an important part

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Tax Controversy – Impact Of ‘Disruptive’ Digitalization Processes on Taxpayers

In a world that is moving at a fast pace in the light of the “disruptive” digitalization processes happening at

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Zimmer Ltd. vs. Germany (2018): Implications for International Taxation and Transfer Pricing

Explore our detailed analysis of the Zimmer Ltd. vs. Germany (2018) case. Learn how this ECJ judgment impacts the definition of Permanent…

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