Czech Republic vs RR Donnelley Transfer Pricing Case
The case Czech Republic vs. RR Donnelley Czech s.r.o. revolved around a transfer pricing dispute concerning the application of Section 23(7) of the Cz…
Tag: MNE Compliance
UK vs Royal Bank of Canada: International Tax Case
This case examines whether payments received by the Royal Bank of Canada (RBC) under an oil exploration agreement were subject to UK taxation. The cor…
Expert Workshop: Safeguarding Tax Strategies – The Power of Attorney-Client Privilege in a Tax Steering Committee
By integrating legal counsel into the TSC, companies can invoke attorney-client privilege, creating a "privilege dome" that shields tax planning strat…
Kenya vs Avic International: TRANSFER PRICING CASE
The Tax Appeals Tribunal in Kenya ruled on the case involving AVIC International Beijing (EA) Limited (Appellant) and the Commissioner of Domestic Tax…
RSA vs Wiese & Others: TAX DEBT RECOVERY CASE
The Supreme Court of Appeal of South Africa (SCA) ruled against Christoffel Hendrik Wiese and other appellants in their appeal concerning SARS's effor…
Australia vs PEPSICO: TRANSFER PRICING CASE
This case, decided by the Federal Court of Australia on 30 November 2023, addressed key taxation issues involving royalty withholding tax and diverted…
Italy v. Ilapak SPA Transfer Pricing Case
The Italy v. Ilapark SPA case brings forward critical issues in transfer pricing, specifically the appropriateness of the selected transfer pricing me…
Italy v. Ilapak SPA Transfer Pricing Case
The Italy v. Ilapark SPA case brings forward critical issues in transfer pricing, specifically the appropriateness of the selected transfer pricing me…
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 …
The Thistle Trust vs C. South African Revenue Service: Understanding the Conduit Principle in Multi-Tiered Trusts
In the landmark case of The Thistle Trust v Commissioner for the South African Revenue Service, the Constitutional Court of South Africa was tasked wi…