This case focuses on whether the Netherlands’ national tax law, which restricts the deduction of interest paid on intra-group loans in certain scenarios, is compatible with the freedom of establishment under Article 49 TFEU.
This case involves the European Commission’s ruling that Luxembourg’s tax rulings for ENGIE constituted unlawful state aid, creating tax advantages that contravened the competitive balance required under EU law.
ENGIE vs EU: State Aid Decision in the EU’s Effort to Combat Selective Tax Advantages Read More »
In this insightful address at the 13th Annual Africa Transfer Pricing Summit, Dr. Daniel N Erasmus explores the most pressing trends in transfer pricing across Africa and developing regions.
The Comparable Profit Method (CPM) is a widely used approach in transfer pricing, employed to ensure that transactions between related entities (often within multinational enterprises) align with the arm’s length principle.
Understanding the Comparable Profit Method (CPM) in Transfer Pricing Read More »
The General Court of the European Union ruled in favour of Luxembourg and Amazon, annulling the European Commission’s decision that Luxembourg granted illegal state aid to Amazon through tax rulings.
General Court Judgment in Amazon and Luxembourg v European Commission Read More »
*For clarity, the term Double Tax Treaty (DTT) used in this article has the same meaning as Double Tax Agreement (DTA). Double Tax Treaties (DTTs) are crucial instruments in international taxation, designed to prevent the same income from being taxed in more than one jurisdiction. These treaties are vital for multinationals and tax professionals, as
Understanding Double Tax Treaties: A Comprehensive Guide Read More »
As global trade increases, so does the complexity of transfer pricing arrangements, leading to potential disputes between multinationals and tax authorities. The significance of transfer pricing dispute resolution lies in its ability to prevent double taxation, ensure compliance with global standards, and mitigate the risk of financial penalties.
Effective Transfer Pricing Dispute Resolution Read More »
Business restructuring in transfer pricing is a critical topic for multinationals, tax professionals, and revenue services. It involves significant changes in a company’s structure, operations, or both, that can have a profound impact on its transfer pricing policies. Understanding this concept is crucial for ensuring that multinationals maintain compliant and efficient transfer pricing structures, especially
The Critical Role of Business Restructuring in Transfer Pricing Read More »
The Academy of Tax Law is excited to announce an online Transfer Pricing Conference specifically emphasising Africa. This event will take place in November 2024 and will delve into global transfer pricing issues, highlighting the unique challenges and opportunities within the African context. While final dates are yet to be confirmed, we are committed to
Announcement: Online Transfer Pricing Conference Focused on Africa Read More »
This case involves a dispute over the deductibility of financial costs related to loans taken out by the taxpayer (A…, Sociedade Unipessoal, LDA) to finance the acquisition of a 70% shareholding in a related company (C…). The Portuguese Tax Authority (AT) disallowed the deduction, arguing that these financial costs were not indispensable for generating taxable income.
Sociedade Unipessoal, LDA vs Portugal Read More »
