Analysis of BlackRock HoldCo 5, LLC v HMRC: Transfer Pricing and Unallowable Purpose Test
Explore the key aspects and implications of the BlackRock HoldCo 5, LLC v HMRC case, focusing on transfer pricing and the unallowable purpose test.
Tag: transfer pricing
UK vs. Kwik-Fit Transfer Pricing Case: Implications for Multinationals
Detailed analysis of the UK vs. Kwik-Fit transfer pricing case, its global implications, and the value of expert guidance in transfer pricing matters.
TRANSFER PRICING: INTEREST ON SHAREHOLDER LOANS AND RELATED MATTERS
In this short video, Renier van Rensburg highlights the complexities of transfer pricing interest on shareholder loans and related matters.
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…
Eaton Corporation vs. IRS: Transfer Pricing Dispute
Eaton Corporation, a global manufacturer of electrical and industrial products, faced significant tax disputes with the IRS regarding its transfer pri…
Ferragamo France Transfer Pricing Case: Key Lessons for Luxury Brands
The Ferragamo France transfer pricing case offers valuable insights for luxury goods companies. This landmark ruling highlights the complexities of tr…
Coca-Cola vs. IRS: Landmark Transfer Pricing Dispute
The Coca-Cola transfer pricing dispute is a landmark case between The Coca-Cola Company (TCCC) and the Internal Revenue Service (IRS). The case center…
Transfer pricing in a nutshell: Nigeria
Article by: Udo Udoma & Belo-Osagie Overview Prior to 2012, there was no comprehensive law regulating transfer pricingTransfer pricing is a fundamental concept in international
