Comparability Challenges in Transfer Pricing: Lessons from Key Disputes
Comparability data is the cornerstone of transfer pricing compliance, providing the benchmarks necessary to ensure that intercompany transactions adhe…
Tag: transfer pricing
Economic Substance Over Legal Form: Key Transfer Pricing Challenges and Case Insights
In transfer pricing, the principle of economic substance over legal form has become a cornerstone of tax authority scrutiny and judicial interpretatio…
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…
Aligning with the Arm’s Length Principle: Key Themes and Challenges in Transfer Pricing Disputes
The Arm’s Length Principle (ALP) lies at the core of global transfer pricing rules, designed to ensure that intercompany transactions between relate…
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…
Lessons on ALP, Economic Substance, Documentation, and Comparability Challenges
Transfer pricing remains a critical focus for multinational enterprises (MNEs) and tax authorities alike. At the heart of many disputes lies the quest…
The OECD’s Transfer Pricing Framework for Mineral Pricing
Transfer pricing in the mineral sector is a complex yet crucial aspect of international tax compliance. The OECD has developed a comprehensive framewo…
Transfer Pricing and Profit Attribution to Permanent Establishments: Insights from Recent Cases
In the increasingly complex landscape of international taxation, Transfer Pricing and Profit Attribution to Permanent Establishments (PEs) have emerge…
Dr. Daniel N Erasmus to Address Key Transfer Pricing Challenges at Africa 2024 Conference
Dr. Daniel N Erasmus, a leading expert in international tax law and transfer pricing, will be a key speaker at the upcoming Online Transfer Pricing Co…
Avago Technologies Trading Ltd v/s Director General, MRA Judgment
The Assessment Review Committee (ARC) ruled in favor of the Mauritius Revenue Authority (MRA) in the case of Avago Technologies Trading Ltd (ATTL) v/s…