Slovakia vs Minebea Access Solutions: Transfer Pricing Case
The Minebea Slovakia transfer pricing case highlights the intricate challenges of aligning intra-group transactions with arm's length principles. In t…
Tag: Arms Length Principle
Portugal vs A Mining SA: Transfer Pricing Case
The case concerns a tax dispute between A…, S.A., a Portuguese mining company, and AT - Tax and Customs Authority. At the heart of the issue was the…
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 …
Avago Technologies Trading Ltd v/s Director General, MRA Judgment
The Assessment Review Committee (ARC) ruled in favor of the Mauritius Revenue Authority (MRA) in the case of Avago Technologies Trading Ltd (ATTL) v/s…
Understanding Intra-Group Losses in Transfer Pricing: Key Insights from Recent Cases
Intra-group losses in transfer pricing have become a focal point of legal scrutiny and regulatory enforcement. The recent cases of Dart Sudamericana, …
The Resale Price Method in Major Transfer Pricing Cases
Transfer pricing continues to be a critical issue for multinational corporations. The resale price method (RPM) plays a significant role in many high-…
Intercompany Agreements and Contracts in Transfer Pricing Documentation
Intercompany agreements and contracts are critical elements in transfer pricing, ensuring that transactions between related entities within a multinat…
Keysight Technologies v. Malaysia: Implications for Transfer Pricing and Tax Compliance
The Keysight Technologies Malaysia case underscores the complexities of transfer pricing and tax compliance. By understanding the court's findings and…
Understanding the Profit Split Method (PSM) in Transfer Pricing
The Profit Split Method in Transfer Pricing is a crucial approach used to ensure that transactions between related companies are conducted at arm's le…