Portugal's Top Court Blocks Free Capital Adjustment on Legal Grounds
CASE INFORMATION The Supremo Tribunal Administrativo (Portugal's Supreme Administrative Court) delivered its judgment on 5 June 2026 in…
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When ‘Insurance’ Isn’t: SARS Wins R9.6m Deduction Battle
The Western Cape High Court upheld SARS’s appeal against a Tax Court decision that had allowed Meiring Citrus to deduct R9.6 million as an…
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Swedish Court Rejects Tax Challenge to Electricity Contract Damages
The Swedish Supreme Administrative Court set aside lower-court decisions that had applied the transfer-pricing correction rule to deny…
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French Court Backs Cost-Plus Pricing for LNG Coordination Services
The French Conseil d’État rejected the Minister’s cassation appeal against the Paris Administrative Court of Appeal’s decision granting…
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From Tax Technician to Tax Leader: Why Modern Tax Functions Need Leadership Capability
Technical tax expertise remains essential, but it is no longer enough. Modern tax professionals must lead teams, manage audit readiness,…
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SARS Verification Audits and Section 11 TAA Notices
SARS verification audits may begin as routine requests for supporting documents, but they can quickly develop into additional or estimated…
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Conducting a Transfer Pricing Trial, Audit to Court Playbook
Many transfer pricing teams still treat risk as an annual documentation exercise. Build the local file, update the benchmark, finalise
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A Course for the Tax Leaders of Tomorrow: The Mechanics of Effectively Leading Tax Teams
We are excited to officially launch The Mechanics of Effectively Leading Tax Teams – a postgraduate certificate designed to meet the urgent…
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Expert Workshop: Safeguarding Tax Strategies – The Power of Attorney-Client Privilege in a Tax…
By integrating legal counsel into the TSC, companies can invoke attorney-client privilege, creating a “privilege dome” that shields tax…
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WORKSHOP: Safeguarding Tax Strategies – Setting up an Attorney-Client Privileged Tax Steering…
Join Dr. Daniel N Erasmus and Renier van Rensburg for an online workshop on 12 February 2025, discussing the critical role of a Tax…
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Pakistan vs Interquest Informatics: TRANSFER PRICING CASE
The case revolves around the taxation treatment of receipts received by Interquest Informatics Services, a Netherlands-incorporated…
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Transforming Transfer Pricing Expertise: Postgraduate Programmes for a Globalised Tax Landscape
Master Transfer Pricing with Middlesex University’s postgraduate programmes. Equip yourself with essential skills for a global tax career.
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Italy v. Ilapak SPA Transfer Pricing Case
The Italy v. Ilapark SPA case brings forward critical issues in transfer pricing, specifically the appropriateness of the selected transfer…
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Australia vs SingTel Transfer Pricing Case
The High Court of Australia deliberated on a significant transfer pricing case between Singapore Telecom Australia Investments Pty Ltd…
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Intra-Group Services: Guidelines, Examples, and Risk Management Strategies
Intra-Group Services are an essential aspect of international taxation, and managing them properly can mean the difference between…
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Canada vs Thompson: Exploring the Limits of Solicitor-Client Privilege in Tax Enforcement
In Canada (National Revenue) v. Thompson, the Supreme Court of Canada evaluated the boundary between solicitor-client privilege and the…
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Introduction to International Taxation: Key Concepts & Guidelines
International taxation governs the tax framework applicable to cross-border activities of individuals and corporations. It addresses the…
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Emerging Transfer Pricing Trends in Africa: Insights from Dr. Daniel Erasmus at the 13th Annual…
In this insightful address at the 13th Annual Africa Transfer Pricing Summit, Dr. Daniel N Erasmus explores the most pressing trends in…
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Understanding the Comparable Profit Method (CPM) in Transfer Pricing
The Comparable Profit Method (CPM) is a widely used approach in transfer pricing, employed to ensure that transactions between related…
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Analysis of X BV v Staatssecretaris van Financiën (Case C-585/22): Preventing Tax Fraud Through…
This case focuses on whether the Netherlands’ national tax law, which restricts the deduction of interest paid on intra-group loans in…
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Hyatt International vs. India (ADIT)
Hyatt vs India (ADIT) tackles several pivotal issues regarding the attribution of income to a Permanent Establishment (PE) in India, even…
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European Commission vs Apple and Ireland (Appeal)
The CJEU’s judgment of 10 September 2024 overturned the General Court’s previous ruling, confirming that Ireland’s tax rulings to Apple…
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What is Comparability Analysis in Transfer Pricing?
Comparability Analysis in Transfer Pricing is a cornerstone of ensuring that transactions between related parties in multinational…
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