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…
Tag: PE
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 …
Permanent Establishments and Managing International Tax Risks: Insights from Key Cases
The concept of a Permanent Establishment (PE) is central to international taxation and transfer pricing. When multinational enterprises (MNEs) conduct…
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…
What is a Permanent Establishment, and How is Its Significance in Transfer Pricing?
A Permanent Establishment (PE) refers to a fixed place of business through which a foreign enterprise conducts business in another country. In the con…
Transfer Pricing and Profit Attribution to Permanent Establishments: Insights from Recent Cases
In the increasingly complex landscape of international taxation, Transfer Pricing and Profit Attribution to Permanent Establishments (PEs) have emerge…
Boston Scientific v. CIT (India): Permanent Establishment and TP Implications
This case, heard by the Indian courts, raises significant issues concerning the activities that constitute a PE, especially in relation to multination…
CEPSA’s Transfer Pricing Case: Spain vs Compañía Española de Petróleos (CEPSA)
The Supreme Court ruled on the tax dispute between the Spanish tax authorities and CEPSA concerning the allocation of general management and administr…
Germany vs “MEAT PE”: Taxation of the Domestic Permanent Establishment of a Hungarian Corporation
This case examines the taxation of the domestic permanent establishment of a Hungarian corporation operating in Germany. The central issue revolves ar…
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…