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, …
Category: South America
Transfer Pricing Case: Colombia vs. Industria Nacional de Gaseosas S.A. (INDEGA)
In-depth analysis of the landmark transfer pricing case between Colombia and INDEGA, its implications for multinationals, and how preventative measure…
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…
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
ANTI-AVOIDANCE MEASURES OF GENERAL NATURE AND SCOPE-GAAR AND OTHER RULES
Paper by: Guillermo O. Teijeiro Most countries have either judicial or statutory general anti-avoidance rules (GAAR); Argentina enrols in the second group as GAAR are
PARAGUAY – “Tax treaty overrides: tension between Paraguayan Constitutional Law and the Vienna Convention on the Law of Treaties. An economic and legal analysis of the feasibility of implementing Double Taxation Treaties with uncertain reciprocity” – Lui Carísimo
DTC are binding agreements between usually two States and thus are governed by Public International Law. In the majority of jurisdictions, the introduction of DTC