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…
Tag: tax risk management
Lessons on ALP, Economic Substance, Documentation, and Comparability Challenges
Transfer pricing remains a critical focus for multinational enterprises (MNEs) and tax authorities alike. At the heart of many disputes lies the quest…
Avago Technologies Trading Ltd v/s Director General, MRA Judgment
The Assessment Review Committee (ARC) ruled in favor of the Mauritius Revenue Authority (MRA) in the case of Avago Technologies Trading Ltd (ATTL) v/s…
Case Analysis: Mylan Australia Holding Pty Ltd v Commissioner of Taxation
Detailed analysis of the Federal Court of Australia’s judgment in Mylan Australia Holding Pty Ltd v Commissioner of Taxation [2024] FCA 253, focusin…
Join Our Free Webinar: How to Prepare for a Tax/ TP Audit – July 2nd, 2024
Join our free webinar on July 2nd to learn how to prepare for a tax/ TP audit with expert insights from Dr. Erasmus & Mr. van Rensburg. Secure your sp…
Nokia vs. India: Permanent Establishment and Profit Attribution Dispute
The case revolved around whether Nokia Solutions and Networks Oy had a Permanent Establishment (PE) in India, and whether profits could be attributed …
GlaxoSmithKline v. CIR (Philippines)
In GlaxoSmithKline (GSK) Philippines, Inc. v. Commissioner of Internal Revenue (CIR), the Supreme Court of the Philippines upheld a tax deficiency ass…