Dr Daniel N Erasmus

The Second Session of the Ad Hoc Committee on the UN Tax Convention

Dispute Resolution, FP News, International Tax, OECD, Tax Dispute Resolution, United Nations /

The Second Session of the Ad Hoc Committee on the UN Tax Convention, held from July 29 to August 16, 2024, at the UN Headquarters in New York, was a significant milestone in the effort to establish a United Nations Framework Convention on International Tax Cooperation. The significance of this session lies in its role in advancing global tax reform, particularly by addressing issues such as the fair allocation of taxing rights, combating illicit financial flows, and ensuring that multinational corporations and wealthy individuals pay their fair share of taxes.

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13th Annual SAIT Transfer Pricing Summit 2024: Key Topics and Insights

Africa, FP News, South Africa, Transfer Pricing /

The 13th SAIT (South African Institute for Taxation) Transfer Pricing Summit 2024 is set to be a pivotal event for tax professionals and policymakers across the continent. This summit will address critical issues in transfer pricing, an increasingly significant field in South Africa and Africa’s economic landscape.

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What is a Permanent Establishment, and How is Its Significance in Transfer Pricing?

FP News, International, International Tax, Transfer Pricing /

A Permanent Establishment (PE) refers to a fixed place of business through which a foreign enterprise conducts business in another country. In the context of transfer pricing, a PE plays a crucial role as it determines the taxation rights of a country over the profits of a foreign enterprise.

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The Italian Supreme Court’s Landmark Ruling on Loss-Making Entities: My Take

Dispute Resolution, FP News, International, International Tax, Italy, Tax Dispute Resolution, TP Case Summaries /

In August 2024, the Italian Supreme Court delivered a pivotal ruling on transfer pricing, specifically addressing the inclusion of loss-making entities in comparability analyses. This ruling could hopefully show a significant shift in how transfer pricing is approached, emphasizing a more comprehensive and accurate reflection of market realities.

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The OECD’s Transfer Pricing Framework for Mineral Pricing

FP News, Mining, OECD, Sectors, Transfer Pricing /

Transfer pricing in the mineral sector is a complex yet crucial aspect of international tax compliance. The OECD has developed a comprehensive framework to assist tax administrations and multinational enterprises (MNEs) in determining the correct pricing for minerals in related-party transactions.

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Italian Supreme Court Ruling on Transfer Pricing: Inclusion of Loss-Making Entities in Comparability Analyses

FP News, International, International Tax, Italy, OECD, TP Case Summaries, Transfer Pricing /

The Italian Supreme Court’s 2024 ruling mandates including loss-making entities in transfer pricing comparability analysis, aligning with OECD guidelines.

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Transfer Pricing and Profit Attribution to Permanent Establishments: Insights from Recent Cases

Dispute Resolution, FP News, International, International Tax, Tax Dispute Resolution, Transfer Pricing /

In the increasingly complex landscape of international taxation, Transfer Pricing and Profit Attribution to Permanent Establishments (PEs) have emerged as critical issues. The intricacies involved in appropriately allocating profits to PEs, especially in cross-border scenarios, continue to challenge multinational corporations and tax authorities alike.

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Exchange of information on reportable cross-border tax arrangements: CJEU Judgment in Case C-623/22

Begium, Dispute Resolution, EU, Europe, FP News, International, International Tax, Tax Dispute Resolution, TP Case Summaries /

The judgment in the case C-623/22, issued by the Court of Justice of the European Union (CJEU) on July 29, 2024, primarily addressed the validity of certain provisions of Directive 2011/16/EU as amended by Directive 2018/822, concerning the mandatory automatic exchange of information on reportable cross-border tax arrangements.

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