India vs AON Consulting: TRANSFER PRICING CASE
The High Court of Delhi, in its ruling on AON Consulting Pvt. Ltd. v. Principal Commissioner of Income Tax – 1 and Ors. (ITA 244/2024), addressed a …
Category: International
Czech Republic vs RR Donnelley Transfer Pricing Case
The case Czech Republic vs. RR Donnelley Czech s.r.o. revolved around a transfer pricing dispute concerning the application of Section 23(7) of the Cz…
UK vs Royal Bank of Canada: International Tax Case
This case examines whether payments received by the Royal Bank of Canada (RBC) under an oil exploration agreement were subject to UK taxation. The cor…
Expert Workshop: Safeguarding Tax Strategies – The Power of Attorney-Client Privilege in a Tax Steering Committee
By integrating legal counsel into the TSC, companies can invoke attorney-client privilege, creating a "privilege dome" that shields tax planning strat…
France vs SAS Roger Vivier: TRANSFER PRICING CASE
The judgment revolves around a tax dispute between SAS Roger Vivier Paris, a distributor of luxury goods, and the French tax authorities. The core iss…
India vs SC Lowy P.I. (Lux): International Tax Case
The judgment in SC Lowy P.I. (Lux) S.A.R.L. vs Assistant Commissioner of Income Tax (ACIT) revolved around the denial of treaty benefits under the Dou…
India vs Samsung Electronics: Permanent Establishment Dispute
The High Court of Delhi ruled on appeals filed by the Commissioner of Income Tax (International Taxation) against Samsung Electronics Co. Ltd., challe…
WORKSHOP: Safeguarding Tax Strategies – Setting up an Attorney-Client Privileged Tax Steering Committee
Join Dr. Daniel N Erasmus and Renier van Rensburg for an online workshop on 12 February 2025, discussing the critical role of a Tax Steering Committee…
Sweden vs “CA AB”: TRANSFER PRICING CASE
The case at hand concerns a dispute under the Nordic Tax Convention, a treaty aimed at avoiding double taxation among its signatories. The applicant, …
France vs Foncière Vélizy Rose: TRANSFER PRICING CASE
The Council of State reviewed an appeal by Foncière Vélizy Rose (FVR) regarding the withholding tax on an interim dividend of EUR 3.6 million distri…