Latest tax posts

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…

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…

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…

Sociedade Unipessoal, LDA vs Portugal

This case involves a dispute over the deductibility of financial costs related to loans taken out by the taxpayer (A…, Sociedade…

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…

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…

Skechers USA Inc. vs. USA

The Wisconsin Tax Appeals Commission ruled in favour of the Wisconsin Department of Revenue, affirming its disallowance of royalty…

3M Company v Commissioner of Internal Revenue: U.S. Transfer Pricing and Foreign Legal…

The dispute focused on the income tax treatment of intellectual property (IP) transactions between 3M’s U.S. subsidiaries and its Brazilian…

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…

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…

SAIT TP Summit I/I/T/F Document Download

TANZANIA: Licensing of Tax Consultants – A clog/fetter to taxpayer’s right to representation?

Published by: B&E Ako Law Taxpayers are now required to be represented by licensed tax consultants only. A representation by

SOUTH AFRICA: Think Tax compliance is simple? Think again (PART 2)

The article was written and published by: ReganVanRooy 10 common mistakes in SA corporate tax returns – Part II CLICK

SOUTH AFRICA: Replacement of IT14SD forms – New SARS Verification Process

AUTHOR: Ziyaad Moosa – PKF Octagon (Johannesburg) With effect from 16 September 2022, The South African Revenue Services (SARS) discontinued

NIGERIA: VAT and the Reverse Charge Mechanism in Nigeria

Article by: Abdulateef Olatunji ABDULRAZAQ (Founder, Taxmobile.Online) Introduction Value Added Tax (VAT) is a consumption tax imposed on…

Mozambique – Mandatory Social Security Pardon of Fines and Reduction of Interests

Decree No. 42/2022, of 17 August, was recently approved, adopting measures to ensure support to employer entities and self-employed…

Think Tax compliance is simple? Think again

Article was written and published by: ReganVanRooy 10 common mistakes in SA corporate tax returns – Part I Today and

So is a foreign pension trust not actually a trust? (South African Tax)

Published by: Regan van Rooy Unpacking the recent SARS ruling on foreign pensions On 22 August 2022, the South African

International Tax Bytes: 7 October 2022

ITB is a weekly PodCast by Steve Towers. It covers all major global tax events for any given week. 07

I/I/T/F METHODOLOGY = SUCCESSFUL CASES

The BESPOKE-winning methodology that we teach in our Postgraduate course in Transfer Pricing and International taxation has been tried and

SARS starts to target buyers of luxury goods

Article originally published by NEWS24 The SA Revenue Service (SARS) is investigating luxury-goods purchases as part of a clampdown on

SARS – Being Audited or Selected for Verification

This article was published by South African Revenue Service and the full article is available at:…

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

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