Conducting a Transfer Pricing Trial, Audit to Court Playbook
Many transfer pricing teams still treat risk as an annual documentation exercise. Build the local file, update the benchmark, finalise
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Global tax coverage
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A Course for the Tax Leaders of Tomorrow: The Mechanics of Effectively Leading Tax Teams
We are excited to officially launch The Mechanics of Effectively Leading Tax Teams – a postgraduate certificate designed to meet the urgent…
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Expert Workshop: Safeguarding Tax Strategies – The Power of Attorney-Client Privilege in a Tax…
By integrating legal counsel into the TSC, companies can invoke attorney-client privilege, creating a “privilege dome” that shields tax…
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WORKSHOP: Safeguarding Tax Strategies – Setting up an Attorney-Client Privileged Tax Steering…
Join Dr. Daniel N Erasmus and Renier van Rensburg for an online workshop on 12 February 2025, discussing the critical role of a Tax…
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Transforming Transfer Pricing Expertise: Postgraduate Programmes for a Globalised Tax Landscape
Master Transfer Pricing with Middlesex University’s postgraduate programmes. Equip yourself with essential skills for a global tax career.
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Australia vs SingTel Transfer Pricing Case
The High Court of Australia deliberated on a significant transfer pricing case between Singapore Telecom Australia Investments Pty Ltd…
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Intra-Group Services: Guidelines, Examples, and Risk Management Strategies
Intra-Group Services are an essential aspect of international taxation, and managing them properly can mean the difference between…
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Canada vs Thompson: Exploring the Limits of Solicitor-Client Privilege in Tax Enforcement
In Canada (National Revenue) v. Thompson, the Supreme Court of Canada evaluated the boundary between solicitor-client privilege and the…
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Introduction to International Taxation: Key Concepts & Guidelines
International taxation governs the tax framework applicable to cross-border activities of individuals and corporations. It addresses the…
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Understanding the Comparable Profit Method (CPM) in Transfer Pricing
The Comparable Profit Method (CPM) is a widely used approach in transfer pricing, employed to ensure that transactions between related…
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Analysis of X BV v Staatssecretaris van Financiën (Case C-585/22): Preventing Tax Fraud Through…
This case focuses on whether the Netherlands’ national tax law, which restricts the deduction of interest paid on intra-group loans in…
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Hyatt International vs. India (ADIT)
Hyatt vs India (ADIT) tackles several pivotal issues regarding the attribution of income to a Permanent Establishment (PE) in India, even…
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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…
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What is Comparability Analysis in Transfer Pricing?
Comparability Analysis in Transfer Pricing is a cornerstone of ensuring that transactions between related parties in multinational…
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General Motors v. ACIT, Circle International Taxation 1(3)(1), New Delhi
The Income Tax Appellate Tribunal (ITAT), Delhi Bench, ruled in favour of General Motors USA in a case revolving around the Double Taxation…
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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…
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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…
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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
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Mutual Agreement Procedures (MAP): Key Guidelines
Mutual Agreement Procedures (MAP) are key mechanisms that ensure fair tax treatment in international transactions. They help resolve…
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Effective Transfer Pricing Dispute Resolution
As global trade increases, so does the complexity of transfer pricing arrangements, leading to potential disputes between multinationals…
Read more →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.…
Read more →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…
Read more →Italian Supreme Court Ruling on Transfer Pricing: Inclusion of Loss-Making Entities in…
The Italian Supreme Court’s 2024 ruling mandates including loss-making entities in transfer pricing comparability analysis, aligning with…
Read more →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)…
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