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Latest tax posts

Commentary, playbooks and updates from the Academy and its faculty.

640 articles

How to Prepare a Tax Controversy Roadmap for MNE’s

Learn how to create an effective tax controversy roadmap for multinational enterprises to navigate potential tax disputes and exposures…

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CUP vs TNMM in Italy vs DG: A Transfer Pricing Method Analysis

Analyze the Italy vs DG transfer pricing case, comparing CUP and TNMM methods from tax authority and taxpayer perspectives. Insights from…

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Transfer Pricing Case Analysis: Italy vs Dolce & Gabbana

The Italy vs DG transfer pricing case is a significant ruling that has far-reaching implications for multinational enterprises and tax…

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What is a Country-by-Country Report (CbCR) in Transfer Pricing?

Understand what a country-by-country report (CbCR) is in transfer pricing and why it’s crucial for multinational enterprises with this…

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Creating a Local File in Transfer Pricing Documentation

Discover best practices for creating a local file as part of your transfer pricing documentation. This guide covers key elements,…

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Case Analysis: Mylan Australia Holding Pty Ltd v Commissioner of Taxation

Detailed analysis of the Federal Court of Australia’s judgment in Mylan Australia Holding Pty Ltd v Commissioner of Taxation [2024] FCA…

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Italy vs UFI Filters: Supreme Court Upholds Arm’s Length Pricing

Explore the landmark Italy vs UFI Filters transfer pricing case, its implications for multinationals, and the importance of robust tax risk…

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X Holding Case: Dutch Supreme Court Rules on TP Dispute

Explore the Dutch Supreme Court’s ruling in the X Holding transfer pricing case and its implications for multinational corporations and tax…

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Creating a Master File for Transfer Pricing Documentation

Discover best practices for creating a comprehensive transfer pricing master file to comply with documentation requirements for…

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Analysis of the Transfer Pricing Case: France vs. SAP France

Detailed analysis of the France vs. SAP France transfer pricing case, its implications for multinationals, and preventative measures for…

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Guide to Comparability Analysis in Transfer Pricing

Understand comparability analysis in transfer pricing with this comprehensive guide. Learn the steps, factors, and best practices for…

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Transfer Pricing Case: Colombia vs. Industria Nacional de Gaseosas S.A. (INDEGA)

In-depth analysis of the landmark transfer pricing case between Colombia and INDEGA, its implications for multinationals, and how…

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Join Our Free Webinar: How to Prepare for a Tax/ TP Audit – July 2nd, 2024

Join our free webinar on July 2nd to learn how to prepare for a tax/ TP audit with expert insights from Dr. Erasmus & Mr. van Rensburg.…

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Guide to Functional Analysis in Transfer Pricing

Understand the importance of functional analysis in transfer pricing and how to conduct it effectively for multinational enterprises and…

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Transfer Pricing Case: Czech Republic vs. AHI Oscar S.R.O.

Explore the in-depth analysis of the landmark transfer pricing case between Czech Republic and AHI Oscar S.R.O., highlighting its…

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Essential Components of Transfer Pricing Documentation

Learn what essential elements should be included in transfer pricing documentation to ensure compliance and mitigate risks.

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Arm’s Length Price Examples: A Comprehensive Guide

Learn what an arm’s length price is, with examples and importance for tax compliance. Essential guide for tax professionals and…

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Landmark Transfer Pricing Case: Israel vs. eBay Marketplace Israel Ltd

Discover the landmark transfer pricing case between Israel and eBay Marketplace Israel Ltd., its implications for multinationals, and the…

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The Primary Advantage of Negotiated Transfer Pricing

Discover the primary advantage of a negotiated transfer price and its impact on multinational enterprises. Learn why consulting TRM is…

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Landmark Transfer Pricing Case: France vs. Willink SAS

Review of the landmark transfer pricing case of France vs. Willink SAS, highlighting the importance of functional analysis, robust…

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India’s Evolving Tax Treaty Landscape

Discover how India tax treaty challenges impact foreign investors and how Dr. Daniel N Erasmus’s expert team can help navigate these…

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In-depth Analysis of Ireland’s First Transfer Pricing Case

Discover the critical insights from Ireland’s first transfer pricing case, impacting multinationals and tax authorities worldwide. Learn…

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Understanding the Arm’s Length Principle of Transfer Pricing: A Comprehensive Guide

Explore the arm’s length principle of transfer pricing in-depth with our comprehensive guide tailored for tax professionals and…

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Understanding Management Fees in Transfer Pricing: Key Aspects and Best Practices

Learn about management fees in transfer pricing, including key aspects, challenges, and best practices to ensure compliance with tax…

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