F Taxpayer vs SARS: Procedural Compliance in Tax Disputes
In the matter of F Taxpayer v SARS, the Tax Court of South Africa was tasked with evaluating the procedural compliance and statutory adherence of the …
Tag: MNEs
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 …
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…
The Critical Role of Business Restructuring in Transfer Pricing
Business restructuring in transfer pricingTransfer pricing is a fundamental concept in international taxationFOR MORE INSIGHT ON INTERNATIONAL TAXATION, PLEASE READ THIS ARTICLE: Introduction to International Taxation: Key Concepts & Guidelines International Taxation encompasses the framework of laws, principles, and treaties that govern the tax obligations of individuals and entities engaged in economic activities that span multiple jurisdictions. This field addresses how income, profits, and gains are taxed when operations or investments extend... that defines the pricing methods and rules applied to transactions between related
The Italian Supreme Court’s Landmark Ruling on Loss-Making Entities: My Take
In August 2024, the Italian Supreme Court delivered a pivotal ruling on transfer pricing, specifically addressing the inclusion of loss-making entitie…
Italian Supreme Court Ruling on Transfer Pricing: Inclusion of Loss-Making Entities in Comparability Analyses
The Italian Supreme Court's 2024 ruling mandates including loss-making entities in transfer pricing comparability analysis, aligning with OECD guideli…
Skechers USA Inc. vs. USA
The Wisconsin Tax Appeals Commission ruled in favour of the Wisconsin Department of Revenue, affirming its disallowance of royalty deductions claimed …
Medtronic vs Commissioner of Inland Revenue
The case of Medtronic, Inc. vs. Commissioner of Internal Revenue revolves around the complex issue of transfer pricing, particularly concerning the ap…
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…