Czech Republic vs RR Donnelley Transfer Pricing Case
The case Czech Republic vs. RR Donnelley Czech s.r.o. revolved around a transfer pricing dispute concerning the application of Section 23(7) of the Cz…
Category: Europe
UK vs Royal Bank of Canada: International Tax Case
This case examines whether payments received by the Royal Bank of Canada (RBC) under an oil exploration agreement were subject to UK taxation. The cor…
France vs SAS Roger Vivier: TRANSFER PRICING CASE
The judgment revolves around a tax dispute between SAS Roger Vivier Paris, a distributor of luxury goods, and the French tax authorities. The core iss…
WORKSHOP: Safeguarding Tax Strategies – Setting up an Attorney-Client Privileged Tax Steering Committee
Join Dr. Daniel N Erasmus and Renier van Rensburg for an online workshop on 12 February 2025, discussing the critical role of a Tax Steering Committee…
Sweden vs “CA AB”: TRANSFER PRICING CASE
The case at hand concerns a dispute under the Nordic Tax Convention, a treaty aimed at avoiding double taxation among its signatories. The applicant, …
Denmark vs Accenture: Transfer Pricing Case
The Danish Supreme Court rendered its decision in the case of Accenture A/S v. Danish Ministry of Taxation, upholding the lower court’s judgment. Th…
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…
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…
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…
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 …