Coca-Cola vs. IRS: Landmark Transfer Pricing Dispute
The Coca-Cola transfer pricing dispute is a landmark case between The Coca-Cola Company (TCCC) and the Internal Revenue Service (IRS). The case center…
Category: General
Canada (Her Majesty the Queen) v. Cameco Corporation
The Federal Court of Appeal's ruling in the case between Her Majesty The Queen and Cameco Corporation centers on the application of Canada's transfer …
Mopani Copper Mines PLC v. Zambia Revenue Authority
The Supreme Court of Zambia ruled on the appeal by Mopani Copper Mines PLC against the Zambia Revenue Authority (ZRA) regarding tax assessments for th…
Transfer pricing in a nutshell: Nigeria
Article by: Udo Udoma & Belo-Osagie Overview Prior to 2012, there was no comprehensive law regulating transfer pricingTransfer pricing is a fundamental concept in international
SARS is circulating a section 46 of the Tax Administration Act, 2011 request for relevant material to many multinationals requesting information about their intra-group services.
Article by: Dr Daniel N Erasmus (Pieterse TRM Erasmus Tax Attorneys) SARSThe South African Revenue ServiceThe South African Revenue Service (SARS) is the official tax authority responsible for the administration and enforcement of tax laws in South Africa. It plays a crucial role in managing the country’s fiscal policy by collecting revenue, administering customs, and ensuring compliance with tax legislation. Established under the South African Revenue Service Act, No. 34 of 1997, SARS functions independently... (SARSThe South African Revenue Service (SARS) is the official tax authority responsible for the administration and enforcement of tax laws in South Africa. It plays a crucial role in managing the country’s fiscal policy by collecting revenue, administering customs, and ensuring compliance with tax legislation. Established under the South African Revenue Service Act, No. 34 of 1997, SARS functions independently...) is the official tax authorityTax authorities are fundamental institutions within government frameworks, overseeing tax assessment, collection, and administration. Their operations ensure that tax laws are enforced and public funds are collected efficiently. This article delves into tax authorities' purpose, responsibilities, and structure, offering insights into their essential role in supporting government functions and economic stability. What is a Tax Authority? A tax authority is... responsible for the
Transfer pricing methods in Greece
Article by: Fotodotis Malamas (Bernitsas Law) Accepted methods What transfer pricingTransfer pricing is a fundamental concept in international taxationFOR MORE INSIGHT ON INTERNATIONAL TAXATION, PLEASE READ THIS ARTICLE: Introduction to International Taxation: Key Concepts & Guidelines International Taxation encompasses the framework of laws, principles, and treaties that govern the tax obligations of individuals and entities engaged in economic activities that span multiple jurisdictions. This field addresses how income, profits, and gains are taxed when operations or investments extend... that defines the pricing methods and
Transfer pricing in a nutshell: Israel
Article by: Eyal Bar-Zvi (Herzog Fox & Neeman) Overview Israel’s transfer pricingTransfer pricing is a fundamental concept in international taxationFOR MORE INSIGHT ON INTERNATIONAL TAXATION, PLEASE READ THIS ARTICLE: Introduction to International Taxation: Key Concepts & Guidelines International Taxation encompasses the framework of laws, principles, and treaties that govern the tax obligations of individuals and entities engaged in economic activities that span multiple jurisdictions. This field addresses how income, profits, and gains are taxed when operations or investments extend... that defines the pricing methods
Transfer Pricing Guidance on Financial Transactions
INCLUSIVE FRAMEWORK ON BEPSBEPS stands for “Base Erosion and Profit Shifting”. BEPS refers to tax avoidanceTax avoidance refers to the practice of legally structuring financial activities to minimise tax liability, reducing the amount of tax owed without violating laws. Unlike tax evasion, which is illegal and involves concealing income or misreporting, tax avoidance operates within the framework of the law. Multinational enterprises (MNEs) and individuals often engage in tax planning strategies that reduce tax liabilities... strategies used by multinational enterprisesWhat are Multinational Enterprises (MNEs)? Multinational Enterprises, commonly referred to as MNEs, are corporations that operate in multiple countries through various subsidiaries, branches, or affiliates. These entities maintain a central management structure while leveraging diverse resources, labour markets, and customer bases across borders. The fundamental aspect that distinguishes MNEs from other corporate forms is their cross-border activity, which can include... (MNEsWhat are Multinational Enterprises (MNEs)? Multinational Enterprises, commonly referred to as MNEs, are corporations that operate in multiple countries through various subsidiaries, branches, or affiliates. These entities maintain a central management structure while leveraging diverse resources, labour markets, and customer bases across borders. The fundamental aspect that distinguishes MNEs from other corporate forms is their cross-border activity, which can include...) to exploit gaps and
SARS will now use artificial intelligence to make ‘it hard and costly’ to dodge tax
Article by: James de Villiers SarsThe South African Revenue ServiceThe South African Revenue Service (SARS) is the official tax authority responsible for the administration and enforcement of tax laws in South Africa. It plays a crucial role in managing the country’s fiscal policy by collecting revenue, administering customs, and ensuring compliance with tax legislation. Established under the South African Revenue Service Act, No. 34 of 1997, SARS functions independently... (SARSThe South African Revenue Service (SARS) is the official tax authority responsible for the administration and enforcement of tax laws in South Africa. It plays a crucial role in managing the country’s fiscal policy by collecting revenue, administering customs, and ensuring compliance with tax legislation. Established under the South African Revenue Service Act, No. 34 of 1997, SARS functions independently...) is the official tax authorityTax authorities are fundamental institutions within government frameworks, overseeing tax assessment, collection, and administration. Their operations ensure that tax laws are enforced and public funds are collected efficiently. This article delves into tax authorities' purpose, responsibilities, and structure, offering insights into their essential role in supporting government functions and economic stability. What is a Tax Authority? A tax authority is... responsible for the administration and enforcement of tax lawsTax laws form the backbone of any nation’s revenue system, setting the rules that govern how individuals and corporations contribute financially to support government functions. These laws define the types of taxes, the applicable rates, and the regulations regarding payment and compliance. They also outline the rights and obligations of taxpayers, ensuring a balanced and fair approach to funding public...
Here Are 10 Geo-Political Economic Trends To Watch
Paper by: George Mentz 1. Energy Independence Innovation – Technology has made finding and harvesting oil and gas much more accurate and cost-effective everywhere. Large