Tax Risk Management: Importance of the Tax Steering Committee
Tax Steering Committees (TSCs) are essential for multinational corporations seeking to ensure tax compliance, manage tax risks, and align tax strategi…
Category: Tax Dispute Resolution
How are source rules that consider income from where business is carried on too vague for guidance?
In this video, we explore Brian Arnold's critical perspective on the vagueness of source rules in international taxation, focusing on how the term "wh…
How can one stay updated with evolving local and international tax changes and react promptly?
In this Q&A, we explore strategies to keep up with the ever-evolving world of local and international tax laws. As regulations shift frequently, tax p…
Emerging Transfer Pricing Trends in Africa: Insights from Dr. Daniel Erasmus at the 13th Annual Africa TP Summit
In this insightful address at the 13th Annual Africa Transfer Pricing Summit, Dr. Daniel N Erasmus explores the most pressing trends in transfer prici…
Permanent Establishments and Managing International Tax Risks: Insights from Key Cases
The concept of a Permanent Establishment (PE) is central to international taxation and transfer pricing. When multinational enterprises (MNEs) conduct…
X BV v Staatssecretaris van Financiën (Case C-585/22): Preventing Tax Fraud Through Arm’s Length Scrutiny
This case focuses on whether the Netherlands' national tax law, which restricts the deduction of interest paid on intra-group loans in certain scenari…
Hyatt International vs. India (ADIT)
Hyatt vs India (ADIT) tackles several pivotal issues regarding the attribution of income to a Permanent Establishment (PE) in India, even in cases whe…
Transfer Pricing and Anti-Abuse Rules: Key Lessons from Recent Judicial Rulings
Transfer pricing and anti-abuse rules have increasingly become focal points for multinationals and tax authorities across the globe. These rules are p…
Expert Transfer Pricing Advocate for Multinational Enterprises
Struggling with complex transfer pricing disputes? As an expert transfer pricing advocate with over 30 years of experience, I specialise in assisting …
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…