X BV v Netherlands (Staatssecretaris van Financiën Case)
The X BV v Staatssecretaris van Financiën case revolves around a key issue in corporate tax: the denial of interest deductions for…
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Global tax coverage
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South Africa’s First Transfer Pricing Case
Explore how TRM’s expertise in transfer pricing challenges in South Africa helped ABD Limited win against SARS, offering insights for…
Read more →South Africa’s first Transfer Pricing case, and it’s a win for the taxpayer!
Can we hear a “woohoo”!? Yes, you read right, South Africa has finally had its first TP case and whaddaya know, the taxpayer won!
Read more →ABD Limited vs. SARS Transfer Pricing Dispute Judgment
Explore the critical analysis of the transfer pricing dispute judgment between ABD Limited and SARS, focusing on IP royalties and tax…
Read more →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…
Read more →Understanding Zambian Transfer Pricing: Insights and Compliance Strategies
Explore the intricacies of Zambian Transfer Pricing, including compliance obligations and strategic insights for navigating these…
Read more →DID YOU MISS THE CONDUCTING A TRANSFER PRICING TRIAL WORKSHOP?
Learn how to best CONDUCT A TRANSFER PRICING TRIAL with leading experts Prof. Dr. Daniel N Erasmus and Mr. Renier van Rensburg from…
Read more →SOUTH AFRICA: The Impact of Global Minimum Corporate Tax on Multinationals
Explore the implications of the new global minimum corporate tax for multinational corporations, including both challenges and…
Read more →Article 26 of the OECD Model Tax Convention Update 2024
The recent approval by the OECD Council of the OECD Model Tax Convention Update 2024 marks a pivotal moment for international tax…
Read more →The Importance of Pillar One’s Amount B
The recent document on Pillar One’s Amount B offers a critical insight into the evolving landscape of global tax regulations, highlighting…
Read more →Exclusive Workshop Invite: Navigating VAT in the Digital Economy
Join us for a critical online workshop, Quo Vadis VAT in a Digitalised World: The Need for Multilateral Coordination, on Wednesday, 28…
Read more →The TPA Transfer Pricing Global Documentation Handbook
The “TPA: Transfer Pricing Global Documentation Handbook – December 2023” is a comprehensive guide for multinational companies navigating…
Read more →BOOK UPDATE: “CONDUCTING A TP TRIAL” – CHAPTER 1 NOW AVAILABLE
Having prepared and argued at numerous Transfer Pricing trials, I thought it a good idea to commit my journey and experiences to paper as a…
Read more →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…
Read more →TRYING TO SETTLE TAX DISPUTES OUTSIDE THE PARAMETERS OF TAX LEGISLATION
This reminds me of a recent issue raised by a client MNE in Africa. The taxpayer was facing a revised tax assessment and had to pay 30% of…
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Apple vs. European Commission
This case revolves around the European Commission’s appeal against the General Court’s decision to annul the Commission’s ruling that…
Read more →Stora Enso Wood Products vs Czechia
The Supreme Administrative Court (SACC) of the Czech Republic annulled the judgment of the Regional Court in Hradec Králové, which had…
Read more →Boston Scientific v. CIT (India): Permanent Establishment and TP Implications
This case, heard by the Indian courts, raises significant issues concerning the activities that constitute a PE, especially in relation to…
Read more →CEPSA’s Transfer Pricing Case: Spain vs Compañía Española de Petróleos (CEPSA)
The Supreme Court ruled on the tax dispute between the Spanish tax authorities and CEPSA concerning the allocation of general management…
Read more →Germany vs “MEAT PE”: Taxation of the Domestic Permanent Establishment of a Hungarian…
This case examines the taxation of the domestic permanent establishment of a Hungarian corporation operating in Germany. The central issue…
Read more →ST Dupont vs. France Transfer Pricing Judgment
ST Dupont, a French luxury manufacturer, contested additional tax assessments and penalties imposed by the French tax authorities for the…
Read more →Germany vs “Z Pipeline”: Transfer Pricing Disputes in Multinational Operations
The FG Düsseldorf judgment of May 12, 2023, revolves around the transfer pricing dispute of a multinational enterprise operating a pipeline…
Read more →Dart Sudamericana Transfer Pricing Case
The case revolves around the transfer pricing methods used by Dart Sudamericana S.A. for the importation of EPS pellets from related…
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Skechers USA Inc. vs. USA
The Wisconsin Tax Appeals Commission ruled in favour of the Wisconsin Department of Revenue, affirming its disallowance of royalty…
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