Understanding the Role of Permanent Establishments in Transfer Pricing
Permanent Establishments (PEs) play a crucial role in the realm of transfer pricing, as they serve as the bridge between international taxation and mu…
Tag: permanent establishments
What is a Permanent Establishment, and How is Its Significance in Transfer Pricing?
A Permanent Establishment (PE) refers to a fixed place of business through which a foreign enterprise conducts business in another country. In the con…
Transfer Pricing and Profit Attribution to Permanent Establishments: Insights from Recent Cases
In the increasingly complex landscape of international taxation, Transfer Pricing and Profit Attribution to Permanent Establishments (PEs) have emerge…
Boston Scientific v. CIT (India): Permanent Establishment and TP Implications
This case, heard by the Indian courts, raises significant issues concerning the activities that constitute a PE, especially in relation to multination…
CEPSA’s Transfer Pricing Case: Spain vs Compañía Española de Petróleos (CEPSA)
The Supreme Court ruled on the tax dispute between the Spanish tax authorities and CEPSA concerning the allocation of general management and administr…
Germany vs “MEAT PE”: Taxation of the Domestic Permanent Establishment of a Hungarian Corporation
This case examines the taxation of the domestic permanent establishment of a Hungarian corporation operating in Germany. The central issue revolves ar…
Germany vs “Z Pipeline”: Transfer Pricing Disputes in Multinational Operations
The FG Düsseldorf judgment of May 12, 2023, revolves around the transfer pricing dispute of a multinational enterprise operating a pipeline network a…
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…
Anwar & Co. v. CIT: Understanding Permanent Establishment in International Taxation
The case of Anwar & Co. v. CIT is a landmark ruling by the Supreme Court of India that delves deep into Permanent Establishment (PE) and its implicati…
Zimmer Ltd. vs. Germany (2018): Implications for International Taxation and Transfer Pricing
Explore our detailed analysis of the Zimmer Ltd. vs. Germany (2018) case. Learn how this ECJ judgment impacts the definition of Permanent Establishmen…