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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Understanding the Role of Permanent Establishments in Transfer Pricing
Permanent Establishments (PEs) play a crucial role in the realm of transfer pricing, as they serve as the bridge between international…
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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…
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The Critical Role of Business Restructuring in Transfer Pricing
Business restructuring in transfer pricing is a critical topic for multinationals, tax professionals, and revenue services. It involves…
Read more →How Changes in Tax Residency Impact South African Trusts
The impact of tax residency on South African trusts introduces several complexities that require meticulous planning. This guide explores…
Read more →The Second Session of the Ad Hoc Committee on the UN Tax Convention
The Second Session of the Ad Hoc Committee on the UN Tax Convention, held from July 29 to August 16, 2024, at the UN Headquarters in New…
Read more →13th Annual SAIT Transfer Pricing Summit 2024: Key Topics and Insights
The 13th SAIT (South African Institute for Taxation) Transfer Pricing Summit 2024 is set to be a pivotal event for tax professionals and…
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 →The OECD’s Transfer Pricing Framework for Mineral Pricing
Transfer pricing in the mineral sector is a complex yet crucial aspect of international tax compliance. The OECD has developed a…
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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Announcement: Online Transfer Pricing Conference Focused on Africa
The Academy of Tax Law is excited to announce an online Transfer Pricing Conference specifically emphasising Africa. This event will
Read more →Dr. Daniel N Erasmus to Address Key Transfer Pricing Challenges at Africa 2024 Conference
Dr. Daniel N Erasmus, a leading expert in international tax law and transfer pricing, will be a key speaker at the upcoming Online Transfer…
Read more →Announcement: Online Transfer Pricing Conference Focused on Africa
The Academy of Tax Law is excited to announce an online Transfer Pricing Conference specifically emphasising Africa. This event will take…
Read more →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…
Read more →Optimised Transfer Pricing Compliance: UNs End-to-End Toolkit
The Transfer Pricing Compliance Assurance – An End-to-End Toolkit developed by the United Nations Subcommittee on Transfer Pricing is a…
Read more →Avago Technologies Trading Ltd v/s Director General, MRA Judgment
The Assessment Review Committee (ARC) ruled in favor of the Mauritius Revenue Authority (MRA) in the case of Avago Technologies Trading Ltd…
Read more →The Importance of Organizational Structure and Business Overview in Transfer Pricing…
The importance of organizational structure and business overview in transfer pricing documentation cannot be overstated. These elements…
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