Understanding the Comparable Profit Method (CPM) in Transfer Pricing
The Comparable Profit Method (CPM) is a widely used approach in transfer pricing, employed to ensure that transactions between related entities (often…
Tag: Dr Daniel N Erasmus
X BV v Staatssecretaris van Financiën (Case C-585/22): Preventing Tax Fraud Through Arm’s Length Scrutiny
This case focuses on whether the Netherlands' national tax law, which restricts the deduction of interest paid on intra-group loans in certain scenari…
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…
Hyatt International vs. India (ADIT)
Hyatt vs India (ADIT) tackles several pivotal issues regarding the attribution of income to a Permanent Establishment (PE) in India, even in cases whe…
Transfer Pricing and Anti-Abuse Rules: Key Lessons from Recent Judicial Rulings
Transfer pricing and anti-abuse rules have increasingly become focal points for multinationals and tax authorities across the globe. These rules are p…
Conducting a Transfer Pricing Trial (eBook)
The book offers a detailed walkthrough of the stages of preparing for and conducting a transfer pricing trial. From assembling a legal and expert team…
General Motors v. ACIT, Circle International Taxation 1(3)(1), New Delhi
The Income Tax Appellate Tribunal (ITAT), Delhi Bench, ruled in favour of General Motors USA in a case revolving around the Double Taxation Avoidance …
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…
Understanding the Global Anti-Base Erosion Model Rules (Pillar Two) and the Importance of Tax Risk Management
In June 2024, the OECD released a document titled "Tax Challenges Arising from the Digitalisation of the Economy – Administrative Guidance on the 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…