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    Home » General » Taxes » Transfer Pricing » Page 4

    Category: Transfer Pricing

    F SCS vs LUXEMBOURG: Safeguarding Lawyer-Client Confidentiality in Cross-Border Tax Inquiries

    This case focuses on whether the Netherlands' national tax law, which restricts the deduction of interest paid on intra-group loans in certain scenari…
    ATL-Editor 28 October 2024

    ENGIE vs EU: State Aid Decision in the EU’s Effort to Combat Selective Tax Advantages

    This case involves the European Commission's ruling that Luxembourg’s tax rulings for ENGIE constituted unlawful state aid, creating tax advantages …
    ATL-Editor 25 October 2024

    Emerging Transfer Pricing Trends in Africa: Insights from Dr. Daniel Erasmus at the 13th Annual Africa TP Summit

    In this insightful address at the 13th Annual Africa Transfer Pricing Summit, Dr. Daniel N Erasmus explores the most pressing trends in transfer prici…
    ATL-Editor 10 October 2024

    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 entities (often…
    ATL-Editor 7 October 2024

    Analysis of X BV v Staatssecretaris van Financiën (Case C-585/22): Preventing Tax Fraud Through Arm’s Length Scrutiny

    This case focuses on whether the Netherlands' national tax law, which restricts the deduction of interest paid on intra-group loans in certain scenari…
    Dr Daniel N Erasmus 5 October 2024

    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 in cases whe…
    Dr Daniel N Erasmus 21 September 2024

    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 Sales Internat…
    Dr Daniel N Erasmus 10 September 2024

    What is Comparability Analysis in Transfer Pricing?

    Comparability Analysis in Transfer Pricing is a cornerstone of ensuring that transactions between related parties in multinational enterprises (MNEs) …
    Dr Daniel N Erasmus 10 September 2024

    Understanding the Role of Permanent Establishments in Transfer Pricing

    Permanent Establishments (PEs) play a crucial role in the realm of transfer pricing, as they serve as the bridge between international taxation and mu…
    Okkie Kellerman 5 September 2024

    General Court Judgment in Amazon and Luxembourg v European Commission

    The General Court of the European Union ruled in favour of Luxembourg and Amazon, annulling the European Commission's decision that Luxembourg granted…
    ATL-Editor 2 September 2024
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