Dart Sudamericana Transfer Pricing Case
The case revolves around the transfer pricing methods used by Dart Sudamericana S.A. for the importation of EPS pellets from related companies. The pr…
Category: International
Skechers USA Inc. vs. USA
The Wisconsin Tax Appeals Commission ruled in favour of the Wisconsin Department of Revenue, affirming its disallowance of royalty deductions claimed …
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 …
Fiat Chrysler Finance Europe and Ireland v Luxembourg: State Aid, Transfer Pricing, and the Arm’s Length Principle
The case involves two appeals by Fiat Chrysler Finance Europe (formerly Fiat Finance and Trade Ltd) and Ireland, challenging the General Court's decis…
Risky Business – 10 things I hate about TP!
Article by: Regan van Rooy Movie buffs will hopefully get the joke intended in this week’s newsletter title, however, if not our other title is
Another TP tax dispute argued before the Tax Board in Tanzania won for our client
The Academy of Tax LawTax laws form the backbone of any nation’s revenue system, setting the rules that govern how individuals and corporations contribute financially
Eaton Corporation vs. IRS: Transfer Pricing Dispute
Eaton Corporation, a global manufacturer of electrical and industrial products, faced significant tax disputes with the IRS regarding its transfer pri…
Medtronic vs Commissioner of Inland Revenue
The case of Medtronic, Inc. vs. Commissioner of Internal Revenue revolves around the complex issue of transfer pricing, particularly concerning the ap…
Ferragamo France Transfer Pricing Case: Key Lessons for Luxury Brands
The Ferragamo France transfer pricing case offers valuable insights for luxury goods companies. This landmark ruling highlights the complexities of tr…
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…