Mutual Agreement Procedures (MAP): Key Guidelines
Mutual Agreement Procedures (MAP) are key mechanisms that ensure fair tax treatment in international transactions. They help resolve conflicts between…
Category: International
Effective Transfer Pricing Dispute Resolution
As global trade increases, so does the complexity of transfer pricing arrangements, leading to potential disputes between multinationals and tax autho…
What is a Permanent Establishment, and How is Its Significance in Transfer Pricing?
A Permanent Establishment (PE) refers to a fixed place of business through which a foreign enterprise conducts business in another country. In the con…
The Italian Supreme Court’s Landmark Ruling on Loss-Making Entities: My Take
In August 2024, the Italian Supreme Court delivered a pivotal ruling on transfer pricing, specifically addressing the inclusion of loss-making entitie…
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…
Transfer Pricing and Profit Attribution to Permanent Establishments: Insights from Recent Cases
In the increasingly complex landscape of international taxation, Transfer Pricing and Profit Attribution to Permanent Establishments (PEs) have emerge…
Dr. Daniel N Erasmus to Address Key Transfer Pricing Challenges at Africa 2024 Conference
Dr. Daniel N Erasmus, a leading expert in international tax law and transfer pricing, will be a key speaker at the upcoming Online Transfer Pricing Co…
Announcement: Online Transfer Pricing Conference Focused on Africa
The Academy of Tax Law is excited to announce an online Transfer Pricing Conference specifically emphasising Africa. This event will take place in Nov…
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…
The Importance of Organizational Structure and Business Overview in Transfer Pricing Documentation
The importance of organizational structure and business overview in transfer pricing documentation cannot be overstated. These elements provide the fo…