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…
Tag: tax dispute resolution
Expert Transfer Pricing Advocate for Multinational Enterprises
Struggling with complex transfer pricing disputes? As an expert transfer pricing advocate with over 30 years of experience, I specialise in assisting …
Conducting a Transfer Pricing Trial (eBook)
The book offers a detailed walkthrough of the stages of preparing for and conducting a transfer pricing trial. From assembling a legal and expert team…
General Motors v. ACIT, Circle International Taxation 1(3)(1), New Delhi
The Income Tax Appellate Tribunal (ITAT), Delhi Bench, ruled in favour of General Motors USA in a case revolving around the Double Taxation Avoidance …
11th Annual Tax Indaba and 13th Annual Transfer Pricing Summit
The 11th Annual Tax Indaba and the 13th Annual Transfer Pricing Summit, produced by the South African Institute for Taxation (SAIT), bring together le…
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…
Dow Chemical Canada ULC v. The King: Tax Court Jurisdiction in Transfer Pricing Disputes
The Dow Chemical Canada case underscores the complex interplay between tax law, administrative discretion, and jurisdictional issues in transfer prici…
X BV v Netherlands (Staatssecretaris van Financiën Case)
The X BV v Staatssecretaris van Financiën case revolves around a key issue in corporate tax: the denial of interest deductions for intra-group loans …
Sociedade Unipessoal, LDA vs Portugal
This case involves a dispute over the deductibility of financial costs related to loans taken out by the taxpayer (A..., Sociedade Unipessoal, LDA) to…
Skechers USA Inc. vs. USA
The Wisconsin Tax Appeals Commission ruled in favour of the Wisconsin Department of Revenue, affirming its disallowance of royalty deductions claimed …