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: tax dispute resolution
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…
India vs Samsung Electronics: Permanent Establishment Dispute
The High Court of Delhi ruled on appeals filed by the Commissioner of Income Tax (International Taxation) against Samsung Electronics Co. Ltd., challe…
Pakistan vs Interquest Informatics: TRANSFER PRICING CASE
The case revolves around the taxation treatment of receipts received by Interquest Informatics Services, a Netherlands-incorporated company, under agr…
Delhi High Court vs ABIC India Pvt. Ltd: TRANSFER PRICING CASE
The High Court of Delhi, in its judgment dated 14 October 2024, upheld the Tribunal’s decision to reinstate the Transactional Net Margin Method (TNM…
Join Our Free Webinar: How to Prepare for a Tax/ TP Audit – July 2nd, 2024
Join our free webinar on July 2nd to learn how to prepare for a tax/ TP audit with expert insights from Dr. Erasmus & Mr. van Rensburg. Secure your sp…
X BV v Netherlands (Staatssecretaris van Financiën Case)
The X BV v Staatssecretaris van Financiën case revolves around a key issue in corporate tax: the denial of interest deductions for intra-group loans …
S.AFRICA: Documentation in tax disputes highlighted in the New dispute resolution rules
Article by Stephen Levetan and Taryn Solomon ENSafrica The new rules promulgated under section 103 of the Tax AdministrationTax authorities are fundamental institutions within government frameworks, overseeing tax