Transforming Transfer Pricing Expertise: Postgraduate Programmes for a Globalised Tax Landscape
Master Transfer Pricing with Middlesex University’s postgraduate programmes. Equip yourself with essential skills for a global tax career.
Introduction to International Taxation: Key Concepts & Guidelines
International taxation governs the tax framework applicable to cross-border activities of individuals and corporations. It addresses the tax treatment of income earned by residents in one country from foreign sources and non-residents from domestic sources.
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Analysis of X BV v Staatssecretaris van Financiën (Case C-585/22): Preventing Tax Fraud Through Arm’s Length Scrutiny
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.
Hyatt International vs. India (ADIT)
Hyatt vs India (ADIT) tackles several pivotal issues regarding the attribution of income to a Permanent Establishment (PE) in India, even in cases where the global entity has incurred financial losses.
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European Commission vs Apple and Ireland (Appeal)
The CJEU’s judgment of 10 September 2024 overturned the General Court’s previous ruling, confirming that Ireland’s tax rulings to Apple Sales International (ASI) and Apple Operations International (AOI) provided an unfair advantage.
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What is Comparability Analysis in Transfer Pricing?
Comparability Analysis in Transfer Pricing is a cornerstone of ensuring that transactions between related parties in multinational enterprises (MNEs) comply with the arm’s length principle, as defined by the OECD and other international bodies.
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General Motors v. ACIT, Circle International Taxation 1(3)(1), New Delhi
The Income Tax Appellate Tribunal (ITAT), Delhi Bench, ruled in favour of General Motors USA in a case revolving around the Double Taxation Avoidance Agreement (DTAA) between India and the USA. The core issue concerned whether the assessee, an LLC, could be considered a “resident” for tax purposes under Article 4 of the India-USA DTAA
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Tax Planning in International Taxation: Navigating Compliance and Avoidance
International Tax Planning is a crucial aspect for multinational corporations seeking to optimize their global tax obligations. With the increasing complexity of international tax laws and regulations, tax planning offers a strategic approach to ensure compliance while minimizing tax liabilities.
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Mutual Agreement Procedures (MAP): Key Guidelines
Mutual Agreement Procedures (MAP) are key mechanisms that ensure fair tax treatment in international transactions. They help resolve conflicts between tax authorities, avoiding double taxation and promoting business growth.
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How Changes in Tax Residency Impact South African Trusts
The impact of tax residency on South African trusts introduces several complexities that require meticulous planning. This guide explores the critical challenges and tax implications associated with changes in tax residency, underlining the need for strategic foresight when managing trusts across different jurisdictions.
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