Poland vs Bedding Textiles: TRANSFER PRICING CASE
The case involves a dispute between N Sp. z o.o. ("the Company"), a Polish textile manufacturer, and the Director of the Tax Administration Chamber in…
Category: Dispute Resolution
France vs Foncière Vélizy Rose: TRANSFER PRICING CASE
The Council of State reviewed an appeal by Foncière Vélizy Rose (FVR) regarding the withholding tax on an interim dividend of EUR 3.6 million distri…
RSA vs Wiese & Others: TAX DEBT RECOVERY CASE
The Supreme Court of Appeal of South Africa (SCA) ruled against Christoffel Hendrik Wiese and other appellants in their appeal concerning SARS's effor…
Australia vs PEPSICO: TRANSFER PRICING CASE
This case, decided by the Federal Court of Australia on 30 November 2023, addressed key taxation issues involving royalty withholding tax and diverted…
Australia vs Oracle: Transfer Pricing Case
This case addressed Oracle Corporation Australia Pty Ltd’s application to temporarily stay domestic court proceedings while a Mutual Agreement Proce…
UK vs Glencore Energy: Transfer Pricing Case
This case examines the boundaries of judicial review in tax disputes involving the Diverted Profits Tax (DPT), a tax introduced by the Finance Act 201…
Canada vs General Electric Capital Canada: Transfer Pricing Case
The case of Canada v. General Electric Capital Canada Inc. (2010 FCA 344) revolved around whether guarantee fees paid by GE Canada to its parent compa…
UK vs REFINITIV AND OTHERS (Thomson Reuters): Transfer Pricing Case
The Court of Appeal’s decision in Refinitiv v HMRC is a defining moment in the intersection of transfer pricing and Diverted Profits Tax (DPT). The …
Slovakia vs Minebea Access Solutions: Transfer Pricing Case
The Minebea Slovakia transfer pricing case highlights the intricate challenges of aligning intra-group transactions with arm's length principles. In t…
Italy v. Ilapak SPA Transfer Pricing Case
The Italy v. Ilapark SPA case brings forward critical issues in transfer pricing, specifically the appropriateness of the selected transfer pricing me…