Delhi High Court vs ABIC India Pvt. Ltd: TRANSFER PRICING CASE
The High Court of Delhi, in its judgment dated 14 October 2024, upheld the Tribunal’s decision to reinstate the Transactional Net Margin Method (TNM…
Tag: International Tax
RSA (CSARS) vs Wiese & Others: TAX DEBT RECOVERY CASE
The Supreme Court of Appeal of South Africa (SCA) ruled against Christoffel Hendrik Wiese and other appellants in their appeal concerning SARS's effor…
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 …
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 REFINITIV AND OTHERS (Thomson Reuters): Transfer Pricing Case
The Court of Appeal’s decision in Refinitiv v HMRC is a defining moment in the intersection of transfer pricing and Diverted Profits Tax (DPT). The …
Transforming Transfer Pricing Expertise: Postgraduate Programmes for a Globalised Tax Landscape
Master Transfer Pricing with Middlesex University's postgraduate programmes. Equip yourself with essential skills for a global tax career.
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…
A Comparative Analysis of Insurance Premium Deductibility
The question of whether insurance premiums are deductible expenses under tax law presents complex challenges, especially when those premiums involve e…
F Taxpayer vs SARS: Procedural Compliance in Tax Disputes
In the matter of F Taxpayer v SARS, the Tax Court of South Africa was tasked with evaluating the procedural compliance and statutory adherence of the …
Boerdery v SARS: Assessing Deductibility of Premiums
In Boerdery v SARS, the South African Tax Court addressed whether premiums paid by Boerdery under insurance contracts with Company XYZ were deductible…