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 law
A Comparative Analysis of Insurance Premium Deductibility
The question of whether insurance premiums are deductible expenses under tax law presents complex challenges, especially when those premiums involve e…
F Taxpayer vs SARS: Procedural Compliance in Tax Disputes
In the matter of F Taxpayer v SARS, the Tax Court of South Africa was tasked with evaluating the procedural compliance and statutory adherence of the …
Australia vs SNF: In-Depth Summary
The case Commissioner of Taxation v. SNF (Australia) Pty Ltd concerned a dispute over the application of the arm's length principle in the context of …
Australia vs SingTel Transfer Pricing Case
The High Court of Australia deliberated on a significant transfer pricing case between Singapore Telecom Australia Investments Pty Ltd (STAI) and the …
Orde van Vlaamse Balies vs Belgium: Legal Privilege and Cross-Border Tax Reporting Obligations
In Case C-694/20, the European Court of Justice (ECJ) examined the legality of certain reporting obligations imposed on lawyers under Council Directiv…
EU State Aid in Transfer Pricing and its International Relevance
State Aid, an important concept within the European Union's (EU) legal framework, serves to prevent competitive imbalances by prohibiting member state…
ENGIE vs EU: State Aid Decision in the EU’s Effort to Combat Selective Tax Advantages
This case involves the European Commission's ruling that Luxembourg’s tax rulings for ENGIE constituted unlawful state aid, creating tax advantages …
Why is Relinquishing Tax Residency More Scrutinised Than Acquiring It?
In this Q&A, we dive into Brian Arnold’s perspective on why a facts-and-circumstances test is applied more rigorously when a taxpayer gives up resid…
Is double non-taxation a BEPS concern, and can a multilateral instrument prevent it?
In this Q&A session, we explore a scenario involving international double taxation, where domestic tax laws and treaty provisions result in double non…