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…
Tag: Tax Strategy
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 …
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…
Tax Planning in International Taxation: Navigating Compliance and Avoidance
International Tax Planning is a crucial aspect for multinational corporations seeking to optimize their global tax obligations. With the increasing co…
Effective Transfer Pricing Dispute Resolution
As global trade increases, so does the complexity of transfer pricing arrangements, leading to potential disputes between multinationals and tax autho…
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
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…
The Importance of Organizational Structure and Business Overview in Transfer Pricing Documentation
The importance of organizational structure and business overview in transfer pricing documentation cannot be overstated. These elements provide the fo…
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 …
Motorola Inc. vs. India (DCIT)
The case revolves around cross-appeals by Motorola, Ericsson, and Nokia against the Income Tax Department of India, challenging the taxability of reve…