Mastering Transfer Pricing Litigation: A Strategic Imperative for Multinational Enterprises
With audits increasing 79% in intensity and number (EY 2023), transfer pricing litigation has never been more urgent—or more costly. In fact, 40–5…
Category: Dispute Resolution
Mechanics of Tax Risk Management: A Strategic Imperative for Multinationals and Revenue Authorities
Tax risk management has become a strategic priority for multinational enterprises (MNEs) and revenue authorities worldwide. Understanding and effectiv…
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…
UK vs Royal Bank of Canada: International Tax Case
This case examines whether payments received by the Royal Bank of Canada (RBC) under an oil exploration agreement were subject to UK taxation. The cor…
Are You Prepared for an Unexpected Tax Audit in South Africa? How Tax Risk Insurance Can Safeguard Your Business
In today's complex tax environment, businesses and individuals in South Africa face increasing scrutiny from the South African Revenue Service (SARS).…
EXPERT WORKSHOP: How Legal Privilege Strengthens Tax Governance
A Tax Steering Committee (TSC) plays a pivotal role in formulating tax strategies and mitigating risks. However, without legal oversight, sensitive de…
WORKSHOP: Safeguarding Tax Strategies – Setting up an Attorney-Client Privileged Tax Steering Committee
Join Dr. Daniel N Erasmus and Renier van Rensburg for an online workshop on 12 February 2025, discussing the critical role of a Tax Steering Committee…
France vs Foncière Vélizy Rose: TRANSFER PRICING CASE
The Council of State reviewed an appeal by Foncière Vélizy Rose (FVR) regarding the withholding tax on an interim dividend of EUR 3.6 million distri…
RSA (CSARS) 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…
Australia vs PEPSICO: TRANSFER PRICING CASE
This case, decided by the Federal Court of Australia on 30 November 2023, addressed key taxation issues involving royalty withholding tax and diverted…