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    Home » General » Regions » Europe » Page 3

    Category: Europe

    Italian Supreme Court Ruling on Transfer Pricing: Inclusion of Loss-Making Entities in Comparability Analyses

    The Italian Supreme Court's 2024 ruling mandates including loss-making entities in transfer pricing comparability analysis, aligning with OECD guideli…
    Dr Daniel N Erasmus 12 August 2024

    Exchange of information on reportable cross-border tax arrangements: CJEU Judgment in Case C-623/22

    The judgment in the case C-623/22, issued by the Court of Justice of the European Union (CJEU) on July 29, 2024, primarily addressed the validity of c…
    Dr Daniel N Erasmus 5 August 2024

    Understanding Intra-Group Losses in Transfer Pricing: Key Insights from Recent Cases

    Intra-group losses in transfer pricing have become a focal point of legal scrutiny and regulatory enforcement. The recent cases of Dart Sudamericana, …
    Dr Daniel N Erasmus 30 July 2024

    Understanding Non-Recognition in Transfer Pricing

    Explore non-recognition in transfer pricing through landmark cases from Malaysia, Luxembourg, and Denmark. Expert analysis by Prof. Dr. Daniel N. Eras…
    Dr Daniel N Erasmus 8 July 2024

    Danish Supreme Court Upholds Transfer Pricing Adjustment in Maersk Oil Case

    Summary of the Danish Supreme Court's landmark ruling on transfer pricing in the Maersk Oil case, with implications for multinationals and tax authori…
    Dr Daniel N Erasmus 7 July 2024

    Luxembourg vs “LLC AB”: Luxembourg Court Upholds Debt Classification of Interest-Free Loan in Transfer Pricing Case

    Luxembourg court rules interest-free loan qualifies as debt, allowing notional interest deduction in landmark transfer pricing case with implications …
    Dr Daniel N Erasmus 4 July 2024

    Netherlands vs “Lux Credit B.V. – Ruling on Arm’s Length Principle in Intra-Group Financing Case

    Analysis of Dutch court ruling on arm's length principle in intra-group financing. Key insights for multinationals on transfer pricing and tax risk ma…
    Dr Daniel N Erasmus 3 July 2024

    Czech Transfer Pricing Case Highlights Importance of Burden of Proof

    Analysis of the ERT Automotive Bohemia case emphasizses the critical role of the burden of proof in transfer pricing disputes and its implications for…
    Dr Daniel N Erasmus 2 July 2024

    Czech Transfer Pricing Case: ERT Automotive Bohemia Wins Appeal Against Tax Authorities

    Analysis of the Czech transfer pricing case where ERT Automotive Bohemia won against tax authorities, highlighting key issues and implications for mul…
    Dr Daniel N Erasmus 2 July 2024

    CUP vs TNMM in Italy vs DG: A Transfer Pricing Method Analysis

    Analyze the Italy vs DG transfer pricing case, comparing CUP and TNMM methods from tax authority and taxpayer perspectives. Insights from Prof. Dr. Er…
    Dr Daniel N Erasmus 28 June 2024
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