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…
Category: Transfer Pricing
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…
11th Annual Tax Indaba and 13th Annual Transfer Pricing Summit
The 11th Annual Tax Indaba and the 13th Annual Transfer Pricing Summit, produced by the South African Institute for Taxation (SAIT), bring together le…
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…
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…
Exactera’s 2024 TP Symposium
I am pleased to announce that I will be speaking at the upcoming 2024 TP Symposium in Lausanne, Switzerland, on September 17-18. My presentation will …
13th Annual SAIT Transfer Pricing Summit 2024: Key Topics and Insights
The 13th SAIT (South African Institute for Taxation) Transfer Pricing Summit 2024 is set to be a pivotal event for tax professionals and policymaker…
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…
The OECD’s Transfer Pricing Framework for Mineral Pricing
Transfer pricing in the mineral sector is a complex yet crucial aspect of international tax compliance. The OECD has developed a comprehensive framewo…
Italian Supreme Court Ruling on Transfer Pricing: Inclusion of Loss-Making Entities in Comparability Analyses
The Italian Supreme Court's 2024 ruling mandates including loss-making entities in transfer pricing comparability analysis, aligning with OECD guideli…