Italy v. Ilapak SPA Transfer Pricing Case
The Italy v. Ilapark SPA case brings forward critical issues in transfer pricing, specifically the appropriateness of the selected transfer pricing me…
Category: Programmes
F Taxpayer vs SARS: Procedural Compliance in Tax Disputes
In the matter of F Taxpayer v SARS, the Tax Court of South Africa was tasked with evaluating the procedural compliance and statutory adherence of the …
Insights from Boerdery v SARS: Assessing Deductibility of Premiums in Farming
In Boerdery v SARS, the South African Tax Court addressed whether premiums paid by Boerdery under insurance contracts with Company XYZ were deductible…
Bechan vs SARS: Search and Seizure Powers of Revenue Authorities
The case of Bechan and Another v SARS Customs Investigations Unit and Others was heard by the Supreme Court of Appeal (SCA) of South Africa, where Mr.…
Australia vs SNF: In-Depth Summary
The case Commissioner of Taxation v. SNF (Australia) Pty Ltd concerned a dispute over the application of the arm's length principle in the context of …
Australia vs SingTel Transfer Pricing Case
The High Court of Australia deliberated on a significant transfer pricing case between Singapore Telecom Australia Investments Pty Ltd (STAI) and the …
Intra-Group Services: Guidelines, Examples, and Risk Management Strategies
Intra-Group Services are an essential aspect of international taxation, and managing them properly can mean the difference between compliance and cost…
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…