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…
Tag: Tax Law
Bechan vs SARS: Search and Seizure Powers of Revenue Authorities
The case of Bechan and Another v SARS Customs Investigations Unit and Others was heard by the Supreme Court of Appeal (SCA) of South Africa, where Mr.…
Lawyer-Client Confidentiality in International Tax: Comparative Analysis of Three Landmark Cases
Lawyer-client confidentiality stands as a pillar of legal protection for both individuals and multinational enterprises (MNEs). This principle, deeply…
The Thistle Trust vs C. South African Revenue Service: Understanding the Conduit Principle in Multi-Tiered Trusts
In the landmark case of The Thistle Trust v Commissioner for the South African Revenue Service, the Constitutional Court of South Africa was tasked wi…
Canada vs Thompson: Exploring the Limits of Attorney-Client Privilege in Tax Enforcement
In Canada (National Revenue) v. Thompson, the Supreme Court of Canada evaluated the boundary between solicitor-client privilege and the statutory obli…
Poulter vs SARS: Taxpayer’s Right to Non-Legal Representation
In the landmark case of Poulter v CSars the Western Cape High Court clarified an essential aspect of taxpayers' rights in South Africa. This case revo…