Poland vs Bedding Textiles: TRANSFER PRICING CASE
The case involves a dispute between N Sp. z o.o. ("the Company"), a Polish textile manufacturer, and the Director of the Tax Administration Chamber in…
Category: Tax Dispute Resolution
PILLAR II: South Africa’s Global Minimum Tax Act – Implications for Multinationals
South Africa has officially gazetted its Global Minimum Tax Act, marking a significant step in aligning its tax legislation with global standards unde…
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…
Transfer Pricing Challenges with TNMM: Lessons from the SABIC India Case for all Multinationals
The SABIC India case revolves around the rejection of TNMM by the Transfer Pricing Officer (TPO) and the adoption of the residual “other method” u…
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…
Documentation and Burden of Proof: Insights from Transfer Pricing Disputes
In transfer pricing disputes, the quality and comprehensiveness of documentation often determine the outcome. Robust documentation not only serves as …
Kenya Revenue Authority’s Guidance on Mutual Agreement Procedure: A Comprehensive Analysis
The Mutual Agreement Procedure, commonly referred to as MAP, is a dispute resolution mechanism that enables contracting states under a DTA to resolve …
Comparability Challenges in Transfer Pricing: Lessons from Key Disputes
Comparability data is the cornerstone of transfer pricing compliance, providing the benchmarks necessary to ensure that intercompany transactions adhe…
Economic Substance Over Legal Form: Key Transfer Pricing Challenges and Case Insights
In transfer pricing, the principle of economic substance over legal form has become a cornerstone of tax authority scrutiny and judicial interpretatio…
Aligning with the Arm’s Length Principle: Key Themes and Challenges in Transfer Pricing Disputes
The Arm’s Length Principle (ALP) lies at the core of global transfer pricing rules, designed to ensure that intercompany transactions between relate…