Mutual Agreement Procedures (MAP): Key Guidelines
Mutual Agreement Procedures (MAP) are key mechanisms that ensure fair tax treatment in international transactions. They help resolve conflicts between…
Category: Dispute Resolution
The Second Session of the Ad Hoc Committee on the UN Tax Convention
The Second Session of the Ad Hoc Committee on the UN Tax Convention, held from July 29 to August 16, 2024, at the UN Headquarters in New York, was a s…
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…
Transfer Pricing and Profit Attribution to Permanent Establishments: Insights from Recent Cases
In the increasingly complex landscape of international taxation, Transfer Pricing and Profit Attribution to Permanent Establishments (PEs) have emerge…
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…
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…
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…