Nokia vs. India: Permanent Establishment and Profit Attribution Dispute
The case revolved around whether Nokia Solutions and Networks Oy had a Permanent Establishment (PE) in India, and whether profits could be…
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Global tax coverage
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Fiat Chrysler Finance Europe and Ireland v Luxembourg: State Aid, Transfer Pricing, and the…
The case involves two appeals by Fiat Chrysler Finance Europe (formerly Fiat Finance and Trade Ltd) and Ireland, challenging the General…
Read more →Risky Business – 10 things I hate about TP!
Article by: Regan van Rooy Movie buffs will hopefully get the joke intended in this week’s newsletter title, however, if
Read more →Another TP tax dispute argued before the Tax Board in Tanzania won for our client
The Academy of Tax Law would like to congratulate the head of our academics, Dr Daniel N. Erasmus, and his
Read more →Eaton Corporation vs. IRS: Transfer Pricing Dispute
Eaton Corporation, a global manufacturer of electrical and industrial products, faced significant tax disputes with the IRS regarding its…
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Medtronic vs Commissioner of Inland Revenue
The case of Medtronic, Inc. vs. Commissioner of Internal Revenue revolves around the complex issue of transfer pricing, particularly…
Read more →Ferragamo France Transfer Pricing Case: Key Lessons for Luxury Brands
The Ferragamo France transfer pricing case offers valuable insights for luxury goods companies. This landmark ruling highlights the…
Read more →UPS Asia Group Pte. Ltd. Case: Transfer Pricing and Permanent EstablishmentUPS Asia Group Pte.…
The case of UPS Asia Group Pte. Ltd. vs. Asstt. Commissioner of Income Tax revolves around the interpretation of whether the applicant had…
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Transfer Pricing Dispute Between Australia and Glencore Investment Pty Ltd
Glencore Australia (CMPL) sold copper concentrate produced in Australia to its Swiss parent, Glencore International AG (GIAG). The tax…
Read more →Transfer Pricing Guidance on Financial Transactions
INCLUSIVE FRAMEWORK ON BEPS: ACTIONS 4, 8-10 Paper by: OECD Please download document here:
Read more →Here Are 10 Geo-Political Economic Trends To Watch
Paper by: George Mentz 1. Energy Independence Innovation – Technology has made finding and harvesting oil and gas much more
Read more →OECD tax proposal gathers pace, but many unanswered questions
Published by Lexology Article by: Macfarlanes LLP – Rhiannon Kinghall Were Last week (9 December) the OECD held a public consultation on
Read more →The OECD opens a public consultation for its proposals on digitalisation of the economy under…
Published by Lexology Article by: Osborne Clarke – Daniel Rioperez and Ana Malagon On November 8, 2019, the OECD published for public…
Read more →OECD: The Global Revenue Statistics Database
The Global Revenue Statistics Database provides the largest public source of harmonised tax revenue data, verified by countries and regional
Read more →The AEOI Standard and Tax Transparency
Source: OECD 2019 is the third year in which jurisdictions have been undertaking the automatic exchange of information on financial
Read more →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…
Read more →Anwar & Co. v. CIT: Understanding Permanent Establishment in International Taxation
The case of Anwar & Co. v. CIT is a landmark ruling by the Supreme Court of India that delves deep into Permanent Establishment (PE) and…
Read more →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…
Read more →GlaxoSmithKline v. CIR (Philippines)
In GlaxoSmithKline (GSK) Philippines, Inc. v. Commissioner of Internal Revenue (CIR), the Supreme Court of the Philippines upheld a tax…
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Chevron Australia Holdings Pty Ltd v Commissioner of Taxation
The Chevron Australia Holdings Pty Ltd v Commissioner of Taxation [2017] FCAFC 62 case is a landmark judgment by the Federal Court of…
Read more →Maruti Suzuki India Ltd. v. ACIT
The Delhi High Court’s ruling in the Maruti Suzuki India Ltd. v. ACIT case is a landmark decision that addresses the complex issue of…
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Xilinx Inc. v. Commissioner of Internal Revenue
The Xilinx Inc. case revolves around whether costs related to employee stock options (ESOs) should be included in the cost-sharing…
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Supreme Court Judgment Analysis: Morgan Stanley & Co. Inc. v. DIT (India)
The case of Morgan Stanley & Co. Inc. v. DIT (India) centered on the determination of whether Morgan Stanley & Co. Inc. (MSCo), a…
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Motorola Inc. vs. India (DCIT)
The case revolves around cross-appeals by Motorola, Ericsson, and Nokia against the Income Tax Department of India, challenging the…
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