Poland vs Bedding Textiles: TRANSFER PRICING CASE
The case involves a dispute between N Sp. z o.o. ("the Company"), a Polish textile manufacturer, and the Director of the Tax Administration Chamber in…
Category: Postgraduate Programmes in International Tax
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…
RSA vs Wiese & Others: TAX DEBT RECOVERY CASE
The Supreme Court of Appeal of South Africa (SCA) ruled against Christoffel Hendrik Wiese and other appellants in their appeal concerning SARS's effor…
The Thistle Trust vs C. South African Revenue Service: Understanding the Conduit Principle in Multi-Tiered Trusts
In the landmark case of The Thistle Trust v Commissioner for the South African Revenue Service, the Constitutional Court of South Africa was tasked wi…
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 statutory obli…
Orde van Vlaamse Balies vs Belgium: Legal Privilege and Cross-Border Tax Reporting Obligations
In Case C-694/20, the European Court of Justice (ECJ) examined the legality of certain reporting obligations imposed on lawyers under Council Directiv…
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 tax treatment…
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…
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…
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) …