The Ferragamo France transfer pricing case offers valuable insights for luxury goods companies. This landmark ruling highlights the complexities of transfer pricing in the high-end retail sector.
Ferragamo France Transfer Pricing Case: Key Lessons for Luxury Brands Read More »
The case of UPS Asia Group Pte. Ltd. vs. Asstt. Commissioner of Income Tax revolves around the interpretation of whether the applicant had a “Business Connection” in India and a “Permanent Establishment” (P.E.) under the India-Singapore Double Taxation Avoidance Agreement (DTAA). The Income Tax Appellate Tribunal (ITAT) ruled in favour of UPS Asia Group, stating that when the Indian Associated Enterprise (A.E.) is remunerated at arm’s length price, no further profit attribution is required, making the existence of a P.E. tax-neutral.
In the case of GE Energy v. CIR (Netherlands), the Dutch Court of Appeal delivered a crucial judgment involving the determination of a Permanent Establishment (PE) in the Netherlands due to the activities of GE Energy’s Libyan subsidiary.
GE Energy v. CIR (Netherlands): Impact of the Libyan Subsidiary on PE Determination Read More »
Glencore Australia (CMPL) sold copper concentrate produced in Australia to its Swiss parent, Glencore International AG (GIAG).
The tax authorities found that the price paid by Glencore International AG to Glencore Australia for the copper concentrate in the relevant years, according to a price-sharing agreement, was less than the price that might reasonably be expected to have been paid in an arm’s length dealing between independent parties.
Transfer Pricing Dispute Between Australia and Glencore Investment Pty Ltd Read More »
In Lexel AB v Skatteverket (Case C‑484/19), the Court of Justice of the European Union (CJEU) ruled that Swedish tax legislation, which denied Lexel AB the right to deduct interest payments made to a group company located in another EU Member State (France), infringed upon the freedom of establishment protected under Article 49 TFEU.
The Coca-Cola transfer pricing dispute is a landmark case between The Coca-Cola Company (TCCC) and the Internal Revenue Service (IRS). The case centers on the appropriate transfer pricing method to allocate profits between Coca-Cola’s U.S. parent company and its foreign subsidiaries. The IRS argued that Coca-Cola’s existing transfer pricing method resulted in underpayment of U.S. taxes, leading to a significant tax deficiency.
Coca-Cola vs. IRS: Landmark Transfer Pricing Dispute Read More »
The Federal Court of Appeal’s ruling in the case between Her Majesty The Queen and Cameco Corporation centers on the application of Canada’s transfer pricing rules, particularly under Section 247 of the Income Tax Act.
Canada (Her Majesty the Queen) v. Cameco Corporation Read More »
The Supreme Court of Zambia ruled on the appeal by Mopani Copper Mines PLC against the Zambia Revenue Authority (ZRA) regarding tax assessments for the charge years 2006/07, 2007/08, and subsequent years. The dispute centered on the transfer pricing practices between Mopani and its shareholder, Glencore International AG (GIAG).
Mopani Copper Mines PLC v. Zambia Revenue Authority Read More »
The case of Anwar & Co. v. CIT is a landmark ruling by the Supreme Court of India that delves deep into Permanent Establishment (PE) and its implications for cross-border taxation. The court was tasked with determining whether the activities of a foreign company in India, facilitated through Anwar & Co., constituted a PE, thereby attracting Indian tax liabilities.
Anwar & Co. v. CIT: Understanding Permanent Establishment in International Taxation Read More »
Explore our detailed analysis of the Zimmer Ltd. vs. Germany (2018) case. Learn how this ECJ judgment impacts the definition of Permanent Establishment and international tax compliance.
