Australia vs Oracle: Transfer Pricing Case
This case addressed Oracle Corporation Australia Pty Ltd’s application to temporarily stay domestic court proceedings while a Mutual Agreement Proce…
Category: Dispute Resolution
UK vs REFINITIV AND OTHERS (Thomson Reuters): Transfer Pricing Case
The Court of Appeal’s decision in Refinitiv v HMRC is a defining moment in the intersection of transfer pricing and Diverted Profits Tax (DPT). The …
Portugal vs A Mining SA: Transfer Pricing Case
The case concerns a tax dispute between A…, S.A., a Portuguese mining company, and AT - Tax and Customs Authority. At the heart of the issue was the…
Italy vs Ilapark: CASE SUMMARY
The Italy v. Ilapark SPA case brings forward critical issues in transfer pricing, specifically the appropriateness of the selected transfer pricing me…
ENGIE vs EU: State Aid Decision in the EU’s Effort to Combat Selective Tax Advantages
This case involves the European Commission's ruling that Luxembourg’s tax rulings for ENGIE constituted unlawful state aid, creating tax advantages …
Tax Risk Management: Importance of the Tax Steering Committee
Tax Steering Committees (TSCs) are essential for multinational corporations seeking to ensure tax compliance, manage tax risks, and align tax strategi…
The Challenge of Blocked Income in Transfer Pricing
The issue of blocked income in transfer pricing arises when multinational enterprises (MNEs) face legal, tax, or regulatory barriers that prevent the …
Permanent Establishments and Managing International Tax Risks: Insights from Key Cases
The concept of a Permanent Establishment (PE) is central to international taxation and transfer pricing. When multinational enterprises (MNEs) conduct…
Understanding the Comparable Profit Method (CPM) in Transfer Pricing
The Comparable Profit Method (CPM) is a widely used approach in transfer pricing, employed to ensure that transactions between related entities (often…
X BV v Staatssecretaris van Financiën (Case C-585/22): Preventing Tax Fraud Through Arm’s Length Scrutiny
This case focuses on whether the Netherlands' national tax law, which restricts the deduction of interest paid on intra-group loans in certain scenari…