The judgment revolves around a tax dispute between SAS Roger Vivier Paris, a distributor of luxury goods, and the French tax authorities. The core issue concerns transfer pricing adjustments made for the financial years 2012–2014, with the tax authorities asserting that SAS Roger Vivier Paris indirectly transferred profits to foreign-related parties in non-arm’s length conditions.
France vs SAS Roger Vivier: TRANSFER PRICING CASE Read More »
The judgment in SC Lowy P.I. (Lux) S.A.R.L. vs Assistant Commissioner of Income Tax (ACIT) revolved around the denial of treaty benefits under the Double Taxation Avoidance Agreement (DTAA) between India and Luxembourg.
India vs SC Lowy P.I. (Lux): International Tax Case Read More »
The High Court of Delhi ruled on appeals filed by the Commissioner of Income Tax (International Taxation) against Samsung Electronics Co. Ltd., challenging the Income Tax Appellate Tribunal’s (ITAT) earlier decisions.
India vs Samsung Electronics: Permanent Establishment Dispute Read More »
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The case revolves around the taxation treatment of receipts received by Interquest Informatics Services, a Netherlands-incorporated company, under agreements with Schlumberger Seaco, Inc., operating in Pakistan.
Pakistan vs Interquest Informatics: TRANSFER PRICING CASE Read More »
The case at hand concerns a dispute under the Nordic Tax Convention, a treaty aimed at avoiding double taxation among its signatories. The applicant, [Company Name Redacted] AB, received interest income from a related Norwegian entity in 2011 and 2012, which was taxed in Sweden.
Sweden vs “CA AB”: TRANSFER PRICING CASE Read More »
The Tax Appeals Tribunal in Kenya ruled on the case involving AVIC International Beijing (EA) Limited (Appellant) and the Commissioner of Domestic Taxes (Respondent) concerning disputed tax assessments covering Corporation Tax, PAYE, and Withholding Tax (WHT) for the years 2016 to 2023.
Kenya vs Avic International: TRANSFER PRICING CASE Read More »
The Danish Supreme Court rendered its decision in the case of Accenture A/S v. Danish Ministry of Taxation, upholding the lower court’s judgment. The dispute revolved around the transfer pricing arrangements within the Accenture group, particularly concerning cross-border personnel assignments and intellectual property (IP) licensing agreements.
Denmark vs Accenture: Transfer Pricing Case Read More »
The case involves a dispute between N Sp. z o.o. (“the Company”), a Polish textile manufacturer, and the Director of the Tax Administration Chamber in Łódź regarding corporate income tax liabilities for the year 2020.
Poland vs Bedding Textiles: TRANSFER PRICING CASE Read More »
The Council of State reviewed an appeal by Foncière Vélizy Rose (FVR) regarding the withholding tax on an interim dividend of EUR 3.6 million distributed to Vélizy Rose Investment (VRI), a Luxembourg-based entity, which was subsequently paid to Dewnos Investment. The Paris Administrative Court of Appeal had dismissed FVR’s claim to discharge this withholding tax, prompting the appeal.
France vs Foncière Vélizy Rose: TRANSFER PRICING CASE Read More »
