Nokia vs. India: Permanent Establishment and Profit Attribution Dispute
The case revolved around whether Nokia Solutions and Networks Oy had a Permanent Establishment (PE) in India, and whether profits could be attributed …
Category: Transfer Pricing Programmes
Fiat Chrysler Finance Europe and Ireland v Luxembourg: State Aid, Transfer Pricing, and the Arm’s Length Principle
The case involves two appeals by Fiat Chrysler Finance Europe (formerly Fiat Finance and Trade Ltd) and Ireland, challenging the General Court's decis…
Medtronic vs Commissioner of Inland Revenue
The case of Medtronic, Inc. vs. Commissioner of Internal Revenue revolves around the complex issue of transfer pricing, particularly concerning the ap…
Lexel AB v Sweden (Skatteverket): CJEU Ruling on Interest Deductions and Freedom of Establishment
In Lexel AB v Skatteverket (Case C‑484/19), the Court of Justice of the European Union (CJEU) ruled that Swedish tax legislation, which denied Lexel…
Xilinx Inc. v. Commissioner of Internal Revenue
The Xilinx Inc. case revolves around whether costs related to employee stock options (ESOs) should be included in the cost-sharing agreement (CSA) bet…
Cadbury Schweppes vs UK: EU Ruling on Freedom of Establishment and Tax Avoidance
The Cadbury Schweppes case is a seminal ruling in the context of the European Union’s freedom of establishment and the limitations on Member States'…
Motorola Inc. vs. India (DCIT)
The case revolves around cross-appeals by Motorola, Ericsson, and Nokia against the Income Tax Department of India, challenging the taxability of reve…