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…
Tag: Tax Compliance
The OECD’s Transfer Pricing Framework for Mineral Pricing
Transfer pricing in the mineral sector is a complex yet crucial aspect of international tax compliance. The OECD has developed a comprehensive framewo…
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…
Exchange of information on reportable cross-border tax arrangements: CJEU Judgment in Case C-623/22
The judgment in the case C-623/22, issued by the Court of Justice of the European Union (CJEU) on July 29, 2024, primarily addressed the validity of c…
Optimised Transfer Pricing Compliance: UNs End-to-End Toolkit
The Transfer Pricing Compliance Assurance – An End-to-End Toolkit developed by the United Nations Subcommittee on Transfer Pricing is a comprehensiv…
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…
Transfer Pricing Policies and Methodologies in Transfer Pricing Documentation
Transfer pricing policies and methodologies are critical components of transfer pricing documentation, which is essential for multinational corporatio…
Importance of Financial Data and Calculations in Transfer Pricing Documentation
The importance of financial data and calculations in transfer pricing documentation cannot be overstated. Accurate financial information forms the bac…
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 …
Apple vs. European Commission
This case revolves around the European Commission's appeal against the General Court's decision to annul the Commission's ruling that Ireland granted …