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The Importance of the Marcopolo Cases for Understanding the Application of the Brazilian Transfer PricingTransfer pricing is a fundamental concept in international taxation that defines the pricing methods and rules applied to transactions between related entities within a multinational enterprise (MNE). In the context of tax regulations, it governs how prices for goods, services, or intangibles (such as intellectual property) are set when these items are exchanged between different branches, subsidiaries, or affiliates of... More Rules Francisco Lisboa Moreira (Bocater Advogados) and Ana Paula Saunders (Vale S.A.)/July 10, 2019/Leave a comment Brazilian Transfer PricingTransfer pricing is a fundamental concept in international taxationFOR MORE INSIGHT ON INTERNATIONAL TAXATION, PLEASE READ THIS ARTICLE: Introduction to International Taxation: Key Concepts & Guidelines International Taxation encompasses the framework of laws, principles, and treaties that govern the tax obligations of individuals and entities engaged in economic activities that span multiple jurisdictions. This field addresses how income, profits, and gains are taxed when operations or investments extend... More that defines the pricing methods and rules applied to transactions between related entities within a multinational enterprise […]

By FASKEN, The Netherlands In terms of section 64E(1)(a) of the Income TaxIncome Tax is a direct levy imposed by governments on the income generated by individuals, corporations, and other entities within a specific jurisdiction. It serves as a major source of revenue for governments and funds various public expenditures, such as infrastructure projects, healthcare,

Jefferson VanderWolk, Robert O’Hare (Squire Patton Boggs)/June 25, 2019 /Leave a comment On June 9, 2019 the G20 finance ministers endorsed the program of work that was issued by the OECD’s Inclusive Framework on BEPSBEPS stands for “Base Erosion and Profit Shifting”. BEPS refers to tax avoidance strategies used by multinational enterprisesWhat are Multinational Enterprises (MNEs)? Multinational Enterprises, commonly referred to as MNEs, are corporations that operate in multiple countries through various subsidiaries, branches, or affiliates. These entities maintain a central management structure while leveraging diverse resources, labour markets, and customer bases across borders. The fundamental aspect that distinguishes MNEs from other corporate forms is their cross-border activity, which can include... More (MNEsWhat are Multinational Enterprises (MNEs)? Multinational Enterprises, commonly referred to as MNEs, are corporations that operate in multiple countries through various subsidiaries, branches, or affiliates. These entities maintain a central management structure while leveraging diverse resources, labour markets, and customer bases across borders. The fundamental aspect that distinguishes MNEs from other corporate forms is their cross-border activity, which can include... More) to exploit gaps and mismatches

By DLA Piper In our Global Tax Alerts in February 2018 and January 2019 we discussed the Dutch Court of Appeal’s decision which held that dividend distributions from Dutch entities to South African entities are effectively exempt from Dutch dividend withholding tax pursuant to the most favoured nation (MFN) clause in the tax treatyA Double Taxation AgreementA Double Taxation Agreement (DTA), also known as a Double Taxation Treaty (or a Tax Treaty), is an international tax treaty between two or more countries that aims to prevent individuals or businesses from being taxed twice on the same income. With globalisation and the increase in cross-border economic activities, DTAs have become essential tools for promoting trade, investment, and... More (DTAA Double Taxation Agreement (DTA), also known as a Double Taxation Treaty (or a Tax Treaty), is an international tax treaty between two or more countries that aims to prevent individuals or businesses from being taxed twice on the same income. With globalisation and the increase in cross-border economic activities, DTAs have become essential tools for promoting trade, investment, and... More), also

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Cameco Corporation v. The Queen The Tax Court of Canada ruled on Cameco Corporation v. The Queen on 26th September 2018.  The court ruled against Canada Revenue Agency (CRA). Cameco Corporation (“Cameco”) mines and produces uranium.  The Canadian organisation has a long-term contract to sell uranium to Swiss Sub Cameco Europe (“CEL”) which trades the

… the grounds of assessment were unreasonable in two respects, namely the incorrect utilisation of the Net Asset Value (NAV) methodology and the Commissioner’s valuation of the shares as nil: This judgment is useful for arguing against unreasonable conduct by Revenue agencies when they issue TP assessments without following the OECDThe Organisation for Economic Co-operation and Development (OECD) is an international organisation comprising 38 member countries, established to foster economic growth, trade, and development on a global scale. Founded in 1961, the OECD provides a forum for governments to collaborate, share policy experiences, and develop solutions to common economic challenges. The OECD's core mission is to promote policies that improve... More TPGs on methodologies.

VI. Conclusion It is astounding to this writer that in the aftermath of the decision in TJN-A v KRA, the Petitioner chose to wave the victory flag, rather than challenge this problematic judgment in the Court of Appeal. It is difficult to see how a judgment that nullifies a Statutory Instrument intended to bring the

STEVE CHILUNDU Staff Reporter Economists and tax expertsA Tax AdvisorA Tax Advisor is a professional who provides specialised advice to individuals, businesses, and organisations on various tax-related matters. They play a crucial role in guiding clients through complex tax laws and ensuring compliance with the latest regulations while identifying opportunities for tax efficiency. Tax Advisors must stay updated on legislative changes and understand the impact of international tax treaties,... More is a professional who provides specialised advice to individuals, businesses, and organisations on various tax-related matters. They play a crucial role in guiding clients through complex tax lawsTax laws form the backbone of any nation’s revenue system, setting the rules that govern how individuals and corporations contribute financially to support government functions. These laws define the types of taxes, the applicable rates, and the regulations regarding payment and compliance. They also outline the rights and obligations of taxpayers, ensuring a balanced and fair approach to funding public... More and ensuring compliance with the latest regulations while identifying opportunities for tax efficiency. Tax AdvisorsA Tax Advisor is a professional who provides specialised advice to individuals, businesses, and organisations on various tax-related matters. They play a crucial role in guiding clients through complex tax laws and ensuring compliance with the latest regulations while identifying opportunities for tax efficiency. Tax Advisors must stay updated on legislative changes and understand the impact of international tax treaties,... More must stay

http://www.fitindia.org/downloads/digest_of_1350_it_and_tp_cases_2018.pdf The Digest contains 1350 important judgments which were pronounced by Courts and Tribunals in the period from January 2018 to December 2018. o Of these, there are 1150 judgments on Transfer PricingTransfer pricing is a fundamental concept in international taxationFOR MORE INSIGHT ON INTERNATIONAL TAXATION, PLEASE READ THIS ARTICLE: Introduction to International Taxation: Key Concepts & Guidelines International Taxation encompasses the framework of laws, principles, and treaties that govern the tax obligations of individuals and entities engaged in economic activities that span multiple jurisdictions. This field addresses how income, profits, and gains are taxed when operations or investments extend... More that defines the pricing methods and rules applied to transactions between related entities within