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    Home » arms length principle

    Tag: arms length principle

    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…
    Dr Daniel N Erasmus 5 October 2024

    European Commission vs Apple and Ireland (Appeal)

    The CJEU's judgment of 10 September 2024 overturned the General Court's previous ruling, confirming that Ireland's tax rulings to Apple Sales Internat…
    Dr Daniel N Erasmus 10 September 2024

    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…
    Dr Daniel N Erasmus 5 August 2024

    The Importance of Thorough Economic Analysis in Transfer Pricing

    Discover why thorough economic analysis in transfer pricing is essential for compliance and profit optimization. Learn how experts like TRM can help.
    Dr Daniel N Erasmus 3 July 2024

    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…
    Dr Daniel N Erasmus 22 March 2022

    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 ass…
    Dr Daniel N Erasmus 26 February 2018

    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…
    ATL-Editor 25 March 2010
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