Mastering Transfer Pricing Litigation: A Strategic Imperative for Multinational Enterprises
With audits increasing 79% in intensity and number (EY 2023), transfer pricing litigation has never been more urgent—or more costly. In fact, 40–5…
Tag: Cross Border Taxation
UK vs Royal Bank of Canada: International Tax Case
This case examines whether payments received by the Royal Bank of Canada (RBC) under an oil exploration agreement were subject to UK taxation. The cor…
Pakistan vs Interquest Informatics: TRANSFER PRICING CASE
The case revolves around the taxation treatment of receipts received by Interquest Informatics Services, a Netherlands-incorporated company, under agr…
Kenya Revenue Authority’s Guidance on Mutual Agreement Procedure: A Comprehensive Analysis
The Mutual Agreement Procedure, commonly referred to as MAP, is a dispute resolution mechanism that enables contracting states under a DTA to resolve …
Introduction to International Taxation: Key Concepts & Guidelines
International taxation governs the tax framework applicable to cross-border activities of individuals and corporations. It addresses the tax treatment…
A Comparative Analysis of Anti-Avoidance Measures in Cross-Border Transactions
In international tax law, striking the right balance between anti-avoidance measures and cross-border economic freedoms is an ongoing challenge. Europ…
Q&A: Avoiding Double Taxation on Cross-Border Advisory Fees – An African Example
QUESTION: If Company A is busy with a project (for example, in South Africa) and gets Company B based in Zimbabwe to do advisory work, company A will …
Q&A: Can you give an indication of how the MAP processes work?
QUESTION: Can you give an indication of how the MAP processes work?
F SCS vs LUXEMBOURG: Safeguarding Lawyer-Client Confidentiality in Cross-Border Tax Inquiries
This case focuses on whether the Netherlands' national tax law, which restricts the deduction of interest paid on intra-group loans in certain scenari…
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…