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…
Tag: International Taxation
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…
Can you give examples where domestic tax rules override the UN and OECD Model Treaties?
In this Q&A session, we explore the interaction between domestic tax rules and the provisions of the UN and OECD Model Tax Treaties. While these treat…
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…
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…
The Second Session of the Ad Hoc Committee on the UN Tax Convention
The Second Session of the Ad Hoc Committee on the UN Tax Convention, held from July 29 to August 16, 2024, at the UN Headquarters in New York, was a s…
Anwar & Co. v. CIT: Understanding Permanent Establishment in International Taxation
The case of Anwar & Co. v. CIT is a landmark ruling by the Supreme Court of India that delves deep into Permanent Establishment (PE) and its implicati…