Analysis of BlackRock HoldCo 5, LLC v HMRC: Transfer Pricing and Unallowable Purpose Test
Explore the key aspects and implications of the BlackRock HoldCo 5, LLC v HMRC case, focusing on transfer pricing and the unallowable purpose test.
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UK vs. Kwik-Fit Transfer Pricing Case: Implications for Multinationals
Detailed analysis of the UK vs. Kwik-Fit transfer pricing case, its global implications, and the value of expert guidance in transfer pricing matters.
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Eaton Corporation vs. IRS: Transfer Pricing Dispute
Eaton Corporation, a global manufacturer of electrical and industrial products, faced significant tax disputes with the IRS regarding its transfer pricing practices. The disputes centered around the company’s Advance Pricing Agreements (APAs) with the IRS, which were intended to establish transfer pricing methodologies for transactions between Eaton and its subsidiaries. The APAs were canceled by the IRS, leading to a tax court case in 2017 and an appeal in 2022.
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Ferragamo France Transfer Pricing Case: Key Lessons for Luxury Brands
The Ferragamo France transfer pricing case offers valuable insights for luxury goods companies. This landmark ruling highlights the complexities of transfer pricing in the high-end retail sector.
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UPS Asia Group Pte. Ltd. Case: Transfer Pricing and Permanent EstablishmentUPS Asia Group Pte. Ltd. Case:
The case of UPS Asia Group Pte. Ltd. vs. Asstt. Commissioner of Income Tax revolves around the interpretation of whether the applicant had a “Business Connection” in India and a “Permanent Establishment” (P.E.) under the India-Singapore Double Taxation Avoidance Agreement (DTAA). The Income Tax Appellate Tribunal (ITAT) ruled in favour of UPS Asia Group, stating that when the Indian Associated Enterprise (A.E.) is remunerated at arm’s length price, no further profit attribution is required, making the existence of a P.E. tax-neutral.
Transfer Pricing Dispute Between Australia and Glencore Investment Pty Ltd
Glencore Australia (CMPL) sold copper concentrate produced in Australia to its Swiss parent, Glencore International AG (GIAG).
The tax authorities found that the price paid by Glencore International AG to Glencore Australia for the copper concentrate in the relevant years, according to a price-sharing agreement, was less than the price that might reasonably be expected to have been paid in an arm’s length dealing between independent parties.
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Coca-Cola vs. IRS: Landmark Transfer Pricing Dispute
The Coca-Cola transfer pricing dispute is a landmark case between The Coca-Cola Company (TCCC) and the Internal Revenue Service (IRS). The case centers on the appropriate transfer pricing method to allocate profits between Coca-Cola’s U.S. parent company and its foreign subsidiaries. The IRS argued that Coca-Cola’s existing transfer pricing method resulted in underpayment of U.S. taxes, leading to a significant tax deficiency.
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GlaxoSmithKline v. CIR (Philippines)
In GlaxoSmithKline (GSK) Philippines, Inc. v. Commissioner of Internal Revenue (CIR), the Supreme Court of the Philippines upheld a tax deficiency assessment against GSK Philippines, emphasizing the importance of adhering to transfer pricing regulations. The case was a landmark decision in 2018, underscoring the significance of the arm’s length principle in determining taxable income for multinational corporations.
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Chevron Australia Holdings Pty Ltd v Commissioner of Taxation
The Chevron Australia Holdings Pty Ltd v Commissioner of Taxation [2017] FCAFC 62 case is a landmark judgment by the Federal Court of Australia concerning the application of transfer pricing rules.
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GlaxoSmithKline vs Canada: Transfer Pricing Case
he GlaxoSmithKline transfer pricing case was a landmark decision in Canadian tax law. It involved GSK’s Canadian subsidiary and the Canada Revenue Agency (CRA). The dispute centered on the pricing of ranitidine, the active ingredient in the anti-ulcer drug Zantac.
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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) between Xilinx Inc. and its subsidiary Xilinx Ireland (XI) under U.S. tax regulations.
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