The Supreme Administrative Court (SACC) of the Czech Republic annulled the judgment of the Regional Court in Hradec Králové, which had previously annulled the tax assessment decision of the Odvolací finanční ředitelství against Stora Enso Wood Products Ždírec s.r.o.
Stora Enso Wood Products vs Czechia Read More »
This case, heard by the Indian courts, raises significant issues concerning the activities that constitute a PE, especially in relation to multinational enterprises (MNEs) operating through subsidiaries.
Boston Scientific v. CIT (India): Permanent Establishment and TP Implications Read More »
The Supreme Court ruled on the tax dispute between the Spanish tax authorities and CEPSA concerning the allocation of general management and administration expenses to CEPSA’s Permanent Establishment (PE) in Algeria.
CEPSA’s Transfer Pricing Case: Spain vs Compañía Española de Petróleos (CEPSA) Read More »
This case examines the taxation of the domestic permanent establishment of a Hungarian corporation operating in Germany. The central issue revolves around the adjustment of profits under Section 1(5) of the Foreign Tax Act (AStG), specifically how the relationship between the Hungarian corporation and its German branch was treated for tax purposes.
ST Dupont, a French luxury manufacturer, contested additional tax assessments and penalties imposed by the French tax authorities for the financial years 2009 to 2011. The authorities argued that ST Dupont had transferred profits to its subsidiary in Hong Kong by selling products at lower-than-arm’s-length prices.
ST Dupont vs. France Transfer Pricing Judgment Read More »
The FG Düsseldorf judgment of May 12, 2023, revolves around the transfer pricing dispute of a multinational enterprise operating a pipeline network across Germany, Belgium, and the Netherlands. The court found that the defendant’s method of profit allocation did not align with the arm’s length principle and violated the existing double taxation treaties.
Germany vs “Z Pipeline”: Transfer Pricing Disputes in Multinational Operations Read More »
The case revolves around the transfer pricing methods used by Dart Sudamericana S.A. for the importation of EPS pellets from related companies. The primary contention was whether the Comparable Uncontrolled Price (CUP) method or the Net Transaction Margin Method (NTMM) was appropriate for determining the arm’s length price of these transactions.
Dart Sudamericana Transfer Pricing Case Read More »
The dispute focused on the income tax treatment of intellectual property (IP) transactions between 3M’s U.S. subsidiaries and its Brazilian subsidiary, 3M do Brasil Ltda (3M Brazil), for the tax year 2006.
The case revolved around whether Nokia Solutions and Networks Oy had a Permanent Establishment (PE) in India, and whether profits could be attributed to that PE under the India-Finland Double Taxation Avoidance Agreement (DTAA).
Nokia vs. India: Permanent Establishment and Profit Attribution Dispute Read More »
Eaton Corporation, a global manufacturer of electrical and industrial products, faced significant tax disputes with the IRS regarding its transfer pricing practices. The disputes centered around the company’s Advance Pricing Agreements (APAs) with the IRS, which were intended to establish transfer pricing methodologies for transactions between Eaton and its subsidiaries. The APAs were canceled by the IRS, leading to a tax court case in 2017 and an appeal in 2022.
Eaton Corporation vs. IRS: Transfer Pricing Dispute Read More »
