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 …
Category: Transfer Pricing Programmes
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…
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…
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 …
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…
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…
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…