Poland vs Bedding Textiles: TRANSFER PRICING CASE
The case involves a dispute between N Sp. z o.o. ("the Company"), a Polish textile manufacturer, and the Director of the Tax Administration Chamber in…
Tag: Tax Compliance
PILLAR II: South Africa’s Global Minimum Tax Act – Implications for Multinationals
South Africa has officially gazetted its Global Minimum Tax Act, marking a significant step in aligning its tax legislation with global standards unde…
France vs Foncière Vélizy Rose: TRANSFER PRICING CASE
The Council of State reviewed an appeal by Foncière Vélizy Rose (FVR) regarding the withholding tax on an interim dividend of EUR 3.6 million distri…
Transfer Pricing Challenges with TNMM: Lessons from the SABIC India Case for all Multinationals
The SABIC India case revolves around the rejection of TNMM by the Transfer Pricing Officer (TPO) and the adoption of the residual “other method” u…
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…
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 PEPSICO: TRANSFER PRICING CASE
This case, decided by the Federal Court of Australia on 30 November 2023, addressed key taxation issues involving royalty withholding tax and diverted…
UK vs Glencore Energy: Transfer Pricing Case
This case examines the boundaries of judicial review in tax disputes involving the Diverted Profits Tax (DPT), a tax introduced by the Finance Act 201…
Canada vs General Electric Capital Canada: Transfer Pricing Case
The case of Canada v. General Electric Capital Canada Inc. (2010 FCA 344) revolved around whether guarantee fees paid by GE Canada to its parent compa…