DID YOU MISS THE CONDUCTING A TRANSFER PRICING TRIAL WORKSHOP?
Learn how to best CONDUCT A TRANSFER PRICING TRIAL with leading experts Prof. Dr. Daniel N Erasmus and Mr. Renier van Rensburg from Middlesex Universi…
Category: International Tax
SOUTH AFRICA: The Impact of Global Minimum Corporate Tax on Multinationals
Explore the implications of the new global minimum corporate tax for multinational corporations, including both challenges and opportunities.
Article 26 of the OECD Model Tax Convention Update 2024
The recent approval by the OECD Council of the OECD Model Tax Convention Update 2024 marks a pivotal moment for international tax practitioners and mu…
The Importance of Pillar One’s Amount B
The recent document on Pillar One's Amount B offers a critical insight into the evolving landscape of global tax regulations, highlighting its signifi…
Apple vs. European Commission
This case revolves around the European Commission's appeal against the General Court's decision to annul the Commission's ruling that Ireland granted …
Stora Enso Wood Products vs Czechia
The Supreme Administrative Court (SACC) of the Czech Republic annulled the judgment of the Regional Court in Hradec Králové, which had previously an…
Boston Scientific v. CIT (India): Permanent Establishment and TP Implications
This case, heard by the Indian courts, raises significant issues concerning the activities that constitute a PE, especially in relation to multination…
ST Dupont vs. France Transfer Pricing Judgment
ST Dupont, a French luxury manufacturer, contested additional tax assessments and penalties imposed by the French tax authorities for the financial ye…
Sociedade Unipessoal, LDA vs Portugal
This case involves a dispute over the deductibility of financial costs related to loans taken out by the taxpayer (A..., Sociedade Unipessoal, LDA) to…
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…