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: International
2025 Transfer Pricing Postgraduate Programmes: A Strategic Investment for MNEs and Revenue Authorities
With global tax landscapes continually evolving, comprehensive training is no longer optional—it is essential.
The Transfer Pricing Postgraduate Pr…
Treatment of Tax Transparent Entities Under Pillar Two: Implications for Multinationals and Revenue Authorities
The implementation of Pillar Two represents a paradigm shift in global tax governance. A cornerstone issue that demands careful scrutiny within this t…
2025 USA Transfer Pricing Guide: Navigating the Latest Developments and Compliance Strategies
Transfer pricing (TP) continues to evolve rapidly in the United States, remaining a cornerstone issue for multinational enterprises (MNEs). As we move…
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…
India vs AON Consulting: TRANSFER PRICING CASE
The High Court of Delhi, in its ruling on AON Consulting Pvt. Ltd. v. Principal Commissioner of Income Tax – 1 and Ors. (ITA 244/2024), addressed a …
Navigating Treaty Dynamics: Insights from Postgraduate Diploma in International Tax Q&A Session
For International Tax professionals, understanding the intricacies of treaties is paramount. Recently, a Q&A session with the Academy of Tax Law's Pos…
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).…