Dr. Daniel N. Erasmus - Leading Expert in Tax Law Global Tax Dispute Resolution by TRM Team
  • Home
  • about.us
  • 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
    Sign in
    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
    • 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

    Tag: double tax treaties

    Navigating Treaty Dynamics: Insights from Postgraduate Diploma in International Tax Q&A Session

    For International Tax professionals, understanding the intricacies of treaties is paramount. Recently, a Q&A session with the Academy of Tax Law's Pos…
    Dr Daniel N. Erasmus 12 March 2025

    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…
    Dr Daniel N. Erasmus 4 March 2025

    India vs SC Lowy P.I. (Lux): International Tax Case

    The judgment in SC Lowy P.I. (Lux) S.A.R.L. vs Assistant Commissioner of Income Tax (ACIT) revolved around the denial of treaty benefits under the Dou…
    Dr Daniel N. Erasmus 24 January 2025

    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…
    Dr Daniel N. Erasmus 23 January 2025

    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…
    Dr Daniel N. Erasmus 22 January 2025

    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 …
    Dr Daniel N. Erasmus 13 October 2024

    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?
    Dr Daniel N. Erasmus 13 October 2024

    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 …
    Dr Daniel N. Erasmus 12 October 2024

    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…
    Dr Daniel N. Erasmus 28 August 2024

    Recent Posts

    • Project AmaBillions – A New Project by the South African Revenue Service to collect an additional ZAR 75 Billion! 9 May 2025
    • Mastering Transfer Pricing Litigation: A Strategic Imperative for Multinational Enterprises 28 March 2025
    • 2025 Transfer Pricing Postgraduate Programmes: A Strategic Investment for MNEs and Revenue Authorities 24 March 2025
    • Treatment of Tax Transparent Entities Under Pillar Two: Implications for Multinationals and Revenue Authorities 24 March 2025
    • 2025 USA Transfer Pricing Guide: Navigating the Latest Developments and Compliance Strategies 18 March 2025
    • Mechanics of Tax Risk Management: A Strategic Imperative for Multinationals and Revenue Authorities 17 March 2025

    ARTICLE ARCHIVES

    ARTICLE CATEGORIES

    • Terms & Conditions
    • Privacy Policy
    • Contact Us
    © 2026 - TaxRiskManagement.com
    Manage Cookie Consent
    To provide the best experiences, we use technologies like cookies to store and/or access device information. Consenting to these technologies will allow us to process data such as browsing behavior or unique IDs on this site. Not consenting or withdrawing consent, may adversely affect certain features and functions.
    Functional Always active
    The technical storage or access is strictly necessary for the legitimate purpose of enabling the use of a specific service explicitly requested by the subscriber or user, or for the sole purpose of carrying out the transmission of a communication over an electronic communications network.
    Preferences
    The technical storage or access is necessary for the legitimate purpose of storing preferences that are not requested by the subscriber or user.
    Statistics
    The technical storage or access that is used exclusively for statistical purposes. The technical storage or access that is used exclusively for anonymous statistical purposes. Without a subpoena, voluntary compliance on the part of your Internet Service Provider, or additional records from a third party, information stored or retrieved for this purpose alone cannot usually be used to identify you.
    Marketing
    The technical storage or access is required to create user profiles to send advertising, or to track the user on a website or across several websites for similar marketing purposes.
    • Manage options
    • Manage services
    • Manage {vendor_count} vendors
    • Read more about these purposes
    View preferences
    • {title}
    • {title}
    • {title}