India vs Samsung Electronics: Permanent Establishment Dispute
The High Court of Delhi ruled on appeals filed by the Commissioner of Income Tax (International Taxation) against Samsung Electronics Co. Ltd., challe…
Tag: Comparable Uncontrolled Price Method
Australia vs PEPSICO: TRANSFER PRICING CASE
This case, decided by the Federal Court of Australia on 30 November 2023, addressed key taxation issues involving royalty withholding tax and diverted…
Australia vs Oracle: Transfer Pricing Case
This case addressed Oracle Corporation Australia Pty Ltd’s application to temporarily stay domestic court proceedings while a Mutual Agreement Proce…
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…
Portugal vs A Mining SA: Transfer Pricing Case
The case concerns a tax dispute between A…, S.A., a Portuguese mining company, and AT - Tax and Customs Authority. At the heart of the issue was the…
Italy vs Ilapark: CASE SUMMARY
The Italy v. Ilapark SPA case brings forward critical issues in transfer pricing, specifically the appropriateness of the selected transfer pricing me…
Australia vs SNF: In-Depth Summary
The case Commissioner of Taxation v. SNF (Australia) Pty Ltd concerned a dispute over the application of the arm's length principle in the context of …
Understanding the Comparable Uncontrolled Price (CUP) Method in Transfer Pricing
The Comparable Uncontrolled Price (CUP) Method is one of the primary transfer pricing methods used to determine arm's length prices for transactions b…
The Importance of Thorough Economic Analysis in Transfer Pricing
Discover why thorough economic analysis in transfer pricing is essential for compliance and profit optimization. Learn how experts like TRM can help.
Czech Transfer Pricing Case: ERT Automotive Bohemia Wins Appeal Against Tax Authorities
Analysis of the Czech transfer pricing case where ERT Automotive Bohemia won against tax authorities, highlighting key issues and implications for mul…