Latest tax posts

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

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…

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…

From the Controversy Landscape – Code of Conduct Principles of Tax Authorities vs Tax Payers…

GTC Conference 2022 The introduction of BEPS has changed the landscape of international taxation. It brought about not only legislative

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…

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…

GE Energy v. CIR (Netherlands): Impact of the Libyan Subsidiary on PE Determination

In the case of GE Energy v. CIR (Netherlands), the Dutch Court of Appeal delivered a crucial judgment involving the determination of a…

Denmark vs EAC: Lessons in Transfer Pricing and Currency Restrictions for Multinational…

DOWNLOAD THE FULL SUMMARY IN PDF HERE VIEW THE FULL JUDGMENT HERE Case Information Court: Østre Landsret Case No: BS-12642/2020