India vs AON Consulting: TRANSFER PRICING CASE
The High Court of Delhi, in its ruling on AON Consulting Pvt. Ltd. v. Principal Commissioner of Income Tax – 1 and Ors. (ITA 244/2024), addressed a …
Tag: tnmm
Czech Republic vs RR Donnelley Transfer Pricing Case
The case Czech Republic vs. RR Donnelley Czech s.r.o. revolved around a transfer pricing dispute concerning the application of Section 23(7) of the Cz…
France vs SAS Roger Vivier: TRANSFER PRICING CASE
The judgment revolves around a tax dispute between SAS Roger Vivier Paris, a distributor of luxury goods, and the French tax authorities. The core iss…
Kenya vs Avic International: TRANSFER PRICING CASE
The Tax Appeals Tribunal in Kenya ruled on the case involving AVIC International Beijing (EA) Limited (Appellant) and the Commissioner of Domestic Tax…
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…
UK vs REFINITIV AND OTHERS (Thomson Reuters): Transfer Pricing Case
The Court of Appeal’s decision in Refinitiv v HMRC is a defining moment in the intersection of transfer pricing and Diverted Profits Tax (DPT). The …
Slovakia vs Minebea Access Solutions: Transfer Pricing Case
The Minebea Slovakia transfer pricing case highlights the intricate challenges of aligning intra-group transactions with arm's length principles. In t…
Italy vs Ilapark: CASE SUMMARY
The Italy v. Ilapark SPA case brings forward critical issues in transfer pricing, specifically the appropriateness of the selected transfer pricing me…
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 …