Lessons on ALP, Economic Substance, Documentation, and Comparability Challenges
Transfer pricing remains a critical focus for multinational enterprises (MNEs) and tax authorities alike. At the heart of many disputes lies the quest…
Category: Tax Dispute Resolution
UK vs Glencore Energy: Transfer Pricing Case
This case examines the boundaries of judicial review in tax disputes involving the Diverted Profits Tax (DPT), a tax introduced by the Finance Act 201…
Canada vs General Electric Capital Canada: Transfer Pricing Case
The case of Canada v. General Electric Capital Canada Inc. (2010 FCA 344) revolved around whether guarantee fees paid by GE Canada to its parent compa…
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 …
Slovakia vs Minebea Access Solutions: Transfer Pricing Case
The Minebea Slovakia transfer pricing case highlights the intricate challenges of aligning intra-group transactions with arm's length principles. In t…
Lawyer-Client Confidentiality in International Tax: Comparative Analysis of Three Landmark Cases
Lawyer-client confidentiality stands as a pillar of legal protection for both individuals and multinational enterprises (MNEs). This principle, deeply…
Canada vs Thompson: Exploring the Limits of Attorney-Client Privilege in Tax Enforcement
In Canada (National Revenue) v. Thompson, the Supreme Court of Canada evaluated the boundary between solicitor-client privilege and the statutory obli…
Orde van Vlaamse Balies vs Belgium: Legal Privilege and Cross-Border Tax Reporting Obligations
In Case C-694/20, the European Court of Justice (ECJ) examined the legality of certain reporting obligations imposed on lawyers under Council Directiv…
EU State Aid in Transfer Pricing and its International Relevance
State Aid, an important concept within the European Union's (EU) legal framework, serves to prevent competitive imbalances by prohibiting member state…
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 …