FP News

Skechers USA Inc. vs. USA

The Wisconsin Tax Appeals Commission ruled in favour of the Wisconsin Department of Revenue, affirming its disallowance of royalty deductions claimed by Skechers USA Inc. in relation to intercompany transactions between Skechers and its subsidiary, Skechers USA Inc. II

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3M Company v Commissioner of Internal Revenue: U.S. Transfer Pricing and Foreign Legal Restrictions

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.

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Nokia vs. India: Permanent Establishment and Profit Attribution Dispute

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).

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Fiat Chrysler Finance Europe and Ireland v Luxembourg: State Aid, Transfer Pricing, and the Arm’s Length Principle

The case involves two appeals by Fiat Chrysler Finance Europe (formerly Fiat Finance and Trade Ltd) and Ireland, challenging the General Court’s decision to uphold a European Commission ruling that a tax ruling granted by Luxembourg to Fiat Chrysler Finance Europe constituted unlawful state aid.

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I/I/T/F METHODOLOGY = SUCCESSFUL CASES

The BESPOKE-winning methodology that we teach in our Postgraduate course in 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

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Risky Business – 10 things I hate about TP!

Article by: Regan van Rooy Movie buffs will hopefully get the joke intended in this week’s newsletter title, however, if not our other title is “10 things you need to know about TP”. Transfer pricingTransfer pricing is a fundamental concept in international taxation that defines the pricing methods and rules applied to transactions between related

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Another TP tax dispute argued before the Tax Board in Tanzania won for our client

The Academy of Tax LawTax 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,

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From the Controversy Landscape – Code of Conduct Principles of Tax Authorities vs Tax Payers Rights Being Challenged

GTC Conference 2022 The introduction of BEPSBEPS stands for “Base Erosion and Profit Shifting”. BEPS refers to tax avoidance strategies used by multinational enterprises (MNEs) to exploit gaps and mismatches in the international tax system. By shifting profits from high-tax jurisdictions to low- or no-tax locations, MNEs reduce their overall tax burden, even if little to

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2020/21 Mauritius Budget

BY: Mark Korten – Korten Consulting The Minister of Finance in Mauritius presented the 2020/21 Budget on 11 June 2021. I have waited to see if the Finance Bill that enacts the Budget proposals would be out by now as there is a past precedent in Mauritius of omitting important Budget proposals in the enacting legislation.

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