Dr Daniel N Erasmus

GlaxoSmithKline v. CIR (Philippines)

International, Philippines, Tax Dispute Resolution, TP Case Summaries, Transfer Pricing /

In GlaxoSmithKline (GSK) Philippines, Inc. v. Commissioner of Internal Revenue (CIR), the Supreme Court of the Philippines upheld a tax deficiency assessment against GSK Philippines, emphasizing the importance of adhering to transfer pricing regulations. The case was a landmark decision in 2018, underscoring the significance of the arm’s length principle in determining taxable income for multinational corporations.

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Maruti Suzuki India Ltd. v. ACIT

India, International, Tax Dispute Resolution, TP Case Summaries, Transfer Pricing /

The Delhi High Court’s ruling in the Maruti Suzuki India Ltd. v. ACIT case is a landmark decision that addresses the complex issue of whether Advertisement, Marketing, and Promotion (AMP) expenses incurred by Maruti Suzuki India Ltd. (MSIL) constituted an international transaction under Indian Transfer Pricing (TP) laws.

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Supreme Court Judgment Analysis: Morgan Stanley & Co. Inc. v. DIT (India)

Dispute Resolution, India, International, Tax Dispute Resolution, TP Case Summaries, Transfer Pricing /

The case of Morgan Stanley & Co. Inc. v. DIT (India) centered on the determination of whether Morgan Stanley & Co. Inc. (MSCo), a U.S.-based company, had a Permanent Establishment (PE) in India through its subsidiary, Morgan Stanley Advantage Services Pvt. Ltd. (MSAS).

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Cadbury Schweppes vs UK: EU Ruling on Freedom of Establishment and Tax Avoidance

Case Summaries, EU, FP News, International, International Tax, Postgraduate Programmes in International Tax, Postgraduate Programmes in Transfer Pricing, Tax Dispute Resolution, TP Case Summaries, Transfer Pricing, United Kingdom /

The Cadbury Schweppes case is a seminal ruling in the context of the European Union’s freedom of establishment and the limitations on Member States’ tax authorities to impose tax measures on Controlled Foreign Companies (CFCs).

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Motorola Inc. vs. India (DCIT)

FP News, India, International, International Tax, Permanent Establishment, Postgraduate Programmes in International Tax, Postgraduate Programmes in Transfer Pricing, Tax Dispute Resolution, TP Case Summaries /

The case revolves around cross-appeals by Motorola, Ericsson, and Nokia against the Income Tax Department of India, challenging the taxability of revenues generated from the supply of equipment and software to Indian telecom operators.

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