South Africa’s first Transfer Pricing case, and it’s a win for the taxpayer!
Can we hear a “woohoo”!? Yes, you read right, South Africa has finally had its first TP case and whaddaya know, the taxpayer won!
Category: Tax Dispute Resolution
ABD Limited vs. SARS Transfer Pricing Dispute Judgment
Explore the critical analysis of the transfer pricing dispute judgment between ABD Limited and SARS, focusing on IP royalties and tax implications.
DID YOU MISS THE MASTERING TAX DISPUTE RESOLUTION IN SOUTH AFRICA WORKSHOP?
This workshop was designed to give aspiring and practising tax professionals an overview of what is needed to navigate the complex terrain of tax audi…
Article 26 of the OECD Model Tax Convention Update 2024
The recent approval by the OECD Council of the OECD Model Tax Convention Update 2024 marks a pivotal moment for international tax practitioners and mu…
Exclusive Workshop Invite: Navigating VAT in the Digital Economy
Join us for a critical online workshop, Quo Vadis VAT in a Digitalised World: The Need for Multilateral Coordination, on Wednesday, 28 February, a…
BOOK UPDATE: “CONDUCTING A TP TRIAL” – CHAPTER 1 NOW AVAILABLE
Having prepared and argued at numerous Transfer Pricing trials, I thought it a good idea to commit my journey and experiences to paper as a guide to o…
TRYING TO SETTLE TAX DISPUTES OUTSIDE THE PARAMETERS OF TAX LEGISLATION
This reminds me of a recent issue raised by a client MNE in Africa. The taxpayer was facing a revised tax assessment and had to pay 30% of the revised…
Stora Enso Wood Products vs Czechia
The Supreme Administrative Court (SACC) of the Czech Republic annulled the judgment of the Regional Court in Hradec Králové, which had previously an…
CEPSA’s Transfer Pricing Case: Spain vs Compañía Española de Petróleos (CEPSA)
The Supreme Court ruled on the tax dispute between the Spanish tax authorities and CEPSA concerning the allocation of general management and administr…
Germany vs “MEAT PE”: Taxation of the Domestic Permanent Establishment of a Hungarian Corporation
This case examines the taxation of the domestic permanent establishment of a Hungarian corporation operating in Germany. The central issue revolves ar…