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 …
Category: International Tax
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…
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…
Lexel AB v Sweden (Skatteverket): CJEU Ruling on Interest Deductions and Freedom of Establishment
In Lexel AB v Skatteverket (Case C‑484/19), the Court of Justice of the European Union (CJEU) ruled that Swedish tax legislation, which denied Lexel…
Mopani Copper Mines PLC v. Zambia Revenue Authority
The Supreme Court of Zambia ruled on the appeal by Mopani Copper Mines PLC against the Zambia Revenue Authority (ZRA) regarding tax assessments for th…
Cadbury Schweppes vs UK: EU Ruling on Freedom of Establishment and Tax Avoidance
The Cadbury Schweppes case is a seminal ruling in the context of the European Union’s freedom of establishment and the limitations on Member States'…
Motorola Inc. vs. India (DCIT)
The case revolves around cross-appeals by Motorola, Ericsson, and Nokia against the Income Tax Department of India, challenging the taxability of reve…