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…
Tag: Double Taxation
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…
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?
Q&A: Navigating International Tax Without a Double Tax Treaty: FATCA, BEPS, and Transfer Pricing
QUESTION: What happens if a country (eg Hong Kong) doesn’t have a double tax treaty with the US, but does have an exchange of information agreement …
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…
Mutual Agreement Procedures (MAP): Key Guidelines
Mutual Agreement Procedures (MAP) are key mechanisms that ensure fair tax treatment in international transactions. They help resolve conflicts between…
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…