Boston Scientific v. CIT (India): Permanent Establishment and TP Implications
This case, heard by the Indian courts, raises significant issues concerning the activities that constitute a PE, especially in relation to multination…
Category: Asia
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 attributed …
UPS Asia Group Pte. Ltd. Case: Transfer Pricing and Permanent EstablishmentUPS Asia Group Pte. Ltd. Case:
The case of UPS Asia Group Pte. Ltd. vs. Asstt. Commissioner of Income Tax revolves around the interpretation of whether the applicant had a "Business…
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
Fraudulent Financial Reporting and Companies’ Characteristics: Evidence from Tax Audit
Paper by: Norsiah Ahmad, Juahir Mohd-Nor and Norman Mohd-Saleh Fraudulent financial reporting has become an important issue in accounting profession. The implementation of self assessment
How the Israel tax authorities are interpreting intergroup intangibles exports – ISRAEL TP CASE
Article by Henriette Fuchs (Pearl Cohen Zedek Latzer Baratz) Unlike the taxing authorities in many other countries, the tax authorities of Israel – managing the
Federal Tax Authority issues public clarification on transfer of business in the UAE
Article by: Reggie Mezu, Bastiaan Moossdorff and Laya Aoun-Hani (Baker McKenzie) The UAE Federal Tax AuthorityTax authorities are fundamental institutions within government frameworks, overseeing tax
International Taxation of E-commerce Business Income
Article by: Dr. Dennis Ndonga (Lecturer, Murdoch University Australia) The rapid growth of cross-border e-commerce has challenged the existing international tax principles that are structured
Double Tax Treaties: An Introduction
Paper by: Reuven S. Avi-Yonah The existing network of over 2,500 bilateral double tax treaties (DTTs) represents an important part of international law. The current
Anwar & Co. v. CIT: Understanding Permanent Establishment in International Taxation
The case of Anwar & Co. v. CIT is a landmark ruling by the Supreme Court of India that delves deep into Permanent Establishment (PE) and its implicati…