Conducting a Transfer Pricing Trial (eBook)
The book offers a detailed walkthrough of the stages of preparing for and conducting a transfer pricing trial. From assembling a legal and expert team…
Category: International
European Commission vs Apple and Ireland (Appeal)
The CJEU's judgment of 10 September 2024 overturned the General Court's previous ruling, confirming that Ireland's tax rulings to Apple Sales Internat…
General Motors v. ACIT, Circle International Taxation 1(3)(1), New Delhi
The Income Tax Appellate Tribunal (ITAT), Delhi Bench, ruled in favour of General Motors USA in a case revolving around the Double Taxation Avoidance …
Global Trends in Transfer Pricing Disputes and Their Impact on African Multinational Enterprises
Transfer pricing disputes have become a prominent issue in the international tax landscape, as multinational enterprises (MNEs) seek to align their gl…
Understanding the Global Anti-Base Erosion Model Rules (Pillar Two) and the Importance of Tax Risk Management
In June 2024, the OECD released a document titled "Tax Challenges Arising from the Digitalisation of the Economy – Administrative Guidance on the Gl…
Navigating Mutual Agreement Procedures (MAP): A Comprehensive Guide for South Africa
For businesses operating across borders, including those in South Africa, MAP is essential for avoiding double taxation and ensuring fair treatment un…
SARS’ New ‘Masterstroke’: How South Africa’s Tax Authority is Cracking Down on Taxpayers with Unprecedented Tactics
The South African Revenue Service (SARS) has unveiled a strategic and aggressive move in its ongoing battle against tax evasion. The key development? …
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…
Medtronic vs Commissioner of Inland Revenue
The case of Medtronic, Inc. vs. Commissioner of Internal Revenue revolves around the complex issue of transfer pricing, particularly concerning the ap…
What is a Permanent Establishment, and How is Its Significance in Transfer Pricing?
A Permanent Establishment (PE) refers to a fixed place of business through which a foreign enterprise conducts business in another country. In the con…