South Africa: light at the end of the tunnel? The ConsCourt judgment against the Public Protector
Watch the judgment being delivered here:
https://www.enca.com/news/livestream-concourt-delivers-judgment-mkhwebane-vs-reserve-bank
Watch the judgment being delivered here:
https://www.enca.com/news/livestream-concourt-delivers-judgment-mkhwebane-vs-reserve-bank
Summary of the Davis Tax Committee’s BEPSBEPS stands for "Base Erosion and Profit Shifting". BEPS refers to tax avoidance strategies used by multinational enterprises (MNEs) to exploit gaps and mismatches in the international tax system. By shifting profits from high-tax jurisdictions to low- or no-tax locations, MNEs reduce their overall tax burden, even if little to no economic activity occurs in the low-tax jurisdictions. These practices erode... More Sub-committee General Report released December 2014 by Peter Dachs of ENS Introduction This note provides a summary of
The case Czech Republic vs. RR Donnelley Czech s.r.o. revolved around a transfer pricingTransfer pricing is a fundamental concept in international taxation that defines the pricing methods and rules applied to transactions between related entities within a multinational enterprise (MNE). In the context of tax regulations, it governs how prices for goods, services, or intangibles (such as intellectual property) are set when these items are exchanged between different branches, subsidiaries, or affiliates of... More dispute concerning the application of Section 23(7) of the Czech Income TaxIncome Tax is a direct levy imposed by governments on the income generated by individuals, corporations, and other entities within a specific jurisdiction. It serves as a major source of revenue for governments and funds various public expenditures, such as infrastructure projects, healthcare, education, national security, and welfare programs. The tax is generally calculated as a percentage of the taxable... More Act (ITA). The core issue was whether RR Donnelley Czech s.r.o. had correctly applied the arm’s length principleThe Arm’s Length Principle (ALP) is a cornerstone concept in international taxation and transfer pricing. It requires that transactions between related parties, such as subsidiaries or affiliates within a multinational enterprise (MNE), mirror those that would occur between independent entities under similar circumstances. This principle ensures that each entity within an MNE is compensated fairly and transparently, based on the... More in a transaction involving the purchase of hard disk drives (HDDs) on behalf of Banta Ireland, a related entity.
The High Court of Delhi, in its ruling on AON Consulting Pvt. Ltd. v. Principal Commissioner of Income TaxIncome Tax is a direct levy imposed by governments on the income generated by individuals, corporations, and other entities within a specific jurisdiction. It serves as a major source of revenue for governments and funds various public expenditures, such as infrastructure projects, healthcare, education, national security, and welfare programs. The tax is generally calculated as a percentage of the taxable... More – 1 and Ors. (ITA 244/2024), addressed a crucial transfer pricingTransfer pricing is a fundamental concept in international taxation that defines the pricing methods and rules applied to transactions between related entities within a multinational enterprise (MNE). In the context of tax regulations, it governs how prices for goods, services, or intangibles (such as intellectual property) are set when these items are exchanged between different branches, subsidiaries, or affiliates of... More (TP) dispute concerning the application of Mutual Agreement Procedure (MAP) to transactions not covered under the agreement.
This case examines whether payments received by the Royal Bank of Canada (RBC) under an oil exploration agreement were subject to UK taxation. The core issue concerns the interpretation of Article 6(2) of the UK/Canada Double TaxationDouble Taxation occurs when the same income or financial transaction is taxed twice, typically in different jurisdictions. It can arise in two primary contexts: economic double taxation, where the same income is taxed twice in the hands of different taxpayers, and juridical double taxation, where the same taxpayer is taxed on the same income in more than one country. Double... More Convention 1978, which governs the taxation of income derived from immovable property, including natural resources.
Explore critical insights into managing transfer pricingTransfer pricing is a fundamental concept in international taxation that defines the pricing methods and rules applied to transactions between related entities within a multinational enterprise (MNE). In the context of tax regulations, it governs how prices for goods, services, or intangibles (such as intellectual property) are set when these items are exchanged between different branches, subsidiaries, or affiliates of... More disputes through the Italy vs. ING Bank SpA case, emphasizing compliance and documentation strategies.