Dr. Daniel N. Erasmus - Leading Expert in Tax Law Global Tax Dispute Resolution by TRM Team
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    Dr. Daniel N. Erasmus - Leading Expert in Tax Law Global Tax Dispute Resolution by TRM Team
    Dr. Daniel N. Erasmus - Leading Expert in Tax Law Global Tax Dispute Resolution by TRM Team
    • Home
    • about.us
      • Prof Dr Daniel N Erasmus
    • our.services
      • global.footprint
        • african.tax.law
          • kenya.tax.law
          • malawi.tax.law
          • mauritius.tax.law
          • nigeria.tax.law
          • rsa.tax.law
          • tanzania.tax.law
          • zimbabwe.tax.law
        • eu.tax.law
          • eu.transfer.pricing
        • usa.tax.law
          • 2025 USA Transfer Pricing Guide
          • usa.transfer.pricing
    • our.methodology
    • our.clients
    • associations
      • I/I/T/F Academy of Tax law
    • contact.us

    Category: TP Case Summaries

    Germany vs “MEAT PE”: Taxation of the Domestic Permanent Establishment of a Hungarian Corporation

    This case examines the taxation of the domestic permanent establishment of a Hungarian corporation operating in Germany. The central issue revolves ar…
    Dr Daniel N. Erasmus 9 July 2023

    ST Dupont vs. France Transfer Pricing Judgment

    ST Dupont, a French luxury manufacturer, contested additional tax assessments and penalties imposed by the French tax authorities for the financial ye…
    Dr Daniel N. Erasmus 5 July 2023

    Germany vs “Z Pipeline”: Transfer Pricing Disputes in Multinational Operations

    The FG Düsseldorf judgment of May 12, 2023, revolves around the transfer pricing dispute of a multinational enterprise operating a pipeline network a…
    Dr Daniel N. Erasmus 15 May 2023

    Dart Sudamericana Transfer Pricing Case

    The case revolves around the transfer pricing methods used by Dart Sudamericana S.A. for the importation of EPS pellets from related companies. The pr…
    Dr Daniel N. Erasmus 14 March 2023

    Skechers USA Inc. vs. USA

    The Wisconsin Tax Appeals Commission ruled in favour of the Wisconsin Department of Revenue, affirming its disallowance of royalty deductions claimed …
    Dr Daniel N. Erasmus 27 February 2023

    3M Company v Commissioner of Internal Revenue: U.S. Transfer Pricing and Foreign Legal Restrictions

    The dispute focused on the income tax treatment of intellectual property (IP) transactions between 3M's U.S. subsidiaries and its Brazilian subsidiary…
    Dr Daniel N. Erasmus 9 February 2023

    Nokia vs. India: Permanent Establishment and Profit Attribution Dispute

    The case revolved around whether Nokia Solutions and Networks Oy had a Permanent Establishment (PE) in India, and whether profits could be attributed …
    Dr Daniel N. Erasmus 23 December 2022

    Fiat Chrysler Finance Europe and Ireland v Luxembourg: State Aid, Transfer Pricing, and the Arm’s Length Principle

    The case involves two appeals by Fiat Chrysler Finance Europe (formerly Fiat Finance and Trade Ltd) and Ireland, challenging the General Court's decis…
    Dr Daniel N. Erasmus 10 November 2022

    Eaton Corporation vs. IRS: Transfer Pricing Dispute

    Eaton Corporation, a global manufacturer of electrical and industrial products, faced significant tax disputes with the IRS regarding its transfer pri…
    Dr Daniel N. Erasmus 25 August 2022

    Ferragamo France Transfer Pricing Case: Key Lessons for Luxury Brands

    The Ferragamo France transfer pricing case offers valuable insights for luxury goods companies. This landmark ruling highlights the complexities of tr…
    Dr Daniel N. Erasmus 30 June 2022
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    Recent Posts

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    • Mastering Transfer Pricing Litigation: A Strategic Imperative for Multinational Enterprises 28 March 2025
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    • Treatment of Tax Transparent Entities Under Pillar Two: Implications for Multinationals and Revenue Authorities 24 March 2025

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