Dispute Resolution Archives - Page 9 of 14

Transfer Pricing Case: Czech Republic vs. AHI Oscar S.R.O.

Czech Republic, Dispute Resolution, Europe, International Tax, Tax Dispute Resolution, TP Case Summaries, Transfer Pricing / Dr Daniel N Erasmus

Explore the in-depth analysis of the landmark 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 case between Czech Republic and AHI Oscar S.R.O., highlighting its significance for multinationals and revenue services.

Transfer Pricing Case: Czech Republic vs. AHI Oscar S.R.O. Read More »

Essential Components of Transfer Pricing Documentation

International, International Tax, Questions & Answers, Tax Dispute Resolution, Transfer Pricing / Dr Daniel N Erasmus

Learn what essential elements should be included 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 as intellectual property) are set when these items are exchanged between different branches, subsidiaries, or affiliates of... More documentation to ensure compliance and mitigate risks.

Essential Components of Transfer Pricing Documentation Read More »

The Primary Advantage of Negotiated Transfer Pricing

Dispute Resolution, International, International Tax, Tax Dispute Resolution, Transfer Pricing / Dr Daniel N Erasmus

Discover the primary advantage of a negotiated transfer price and its impact on 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. Learn why consulting TRM is essential for effective management.

The Primary Advantage of Negotiated Transfer Pricing Read More »

In-depth Analysis of Ireland’s First Transfer Pricing Case

Dispute Resolution, Europe, Ireland, TP Case Summaries, Transfer Pricing / Dr Daniel N Erasmus

Discover the critical insights from Ireland’s first 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 case, impacting multinationals and tax authorities worldwide. Learn about the landmark ruling today.

In-depth Analysis of Ireland’s First Transfer Pricing Case Read More »

Insights from Italy vs. ING Bank SpA Transfer Pricing Case

Dispute Resolution / Dr Daniel N Erasmus

Explore critical insights into managing 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 disputes through the Italy vs. ING Bank SpA case, emphasizing compliance and documentation strategies.

Insights from Italy vs. ING Bank SpA Transfer Pricing Case Read More »

Join Us at the GTC Conference 2024 in Milan: Mastering Controversy Roadmaps for MNEs

Dispute Resolution, International, International Tax, Tax Dispute Resolution, Transfer Pricing / Dr Daniel N Erasmus

Discover strategies at the GTC Conference 2024 on creating a controversy roadmap for MNEs. Join us in Milan or online on June 7, 2024.

Join Us at the GTC Conference 2024 in Milan: Mastering Controversy Roadmaps for MNEs Read More »

WORKSHOP: Conducting a Transfer Pricing Trial

International Tax, Tax Dispute Resolution, Transfer Pricing / Dr Daniel N Erasmus

Join our free workshop on 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 trials led by Prof Dr Daniel N Erasmus. Gain insights and strategies for managing royalty rate disputes.

WORKSHOP: Conducting a Transfer Pricing Trial Read More »

Tax Dispute Resolutions: A Case Study on Tresping Manufacturing vs. SARS

Dispute Resolution, South Africa, Tax Dispute Resolution / Dr Daniel N Erasmus

Explore the critical insights from the Tresping Manufacturing vs. SARS case on navigating tax disputes and compliance with customs regulations.

Tax Dispute Resolutions: A Case Study on Tresping Manufacturing vs. SARS Read More »

Landmark Transfer Pricing Case from South Africa

International, International Tax, South Africa, Tax Dispute Resolution, Transfer Pricing / Dr Daniel N Erasmus

TRM Tax Attorneys secures landmark victory in South Africa’s first 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 case, demonstrating expertise in resolving complex tax disputesTax Disputes arise when there is a disagreement between taxpayers and tax authorities regarding the interpretation or application of tax laws. These disputes may concern various issues such as the accuracy of a tax return, the eligibility for tax deductions or credits, the correct amount of tax liability, or transfer pricing adjustments. Tax disputes can lead to lengthy legal proceedings... More. Learn how Prof Dr Daniel N Erasmus and his team can assist you.

Landmark Transfer Pricing Case from South Africa Read More »

X BV v Netherlands (Staatssecretaris van Financiën Case)

EU, FP News, International, Netherlands, OECD, Tax Dispute Resolution, TP Case Summaries, Transfer Pricing / Dr Daniel N Erasmus

The X BV v Staatssecretaris van Financiën case revolves around a key issue in corporate taxCorporate Tax refers to the tax imposed by governments on the income or capital of corporations. Corporations, considered separate legal entities, are taxed on their profits, meaning the income generated from their operational activities, investments, and other financial undertakings. This tax is generally a key revenue source for governments, helping to fund public services, infrastructure, and other essential functions. The... More: the denial of interest deductions for intra-group loans in cross-border transactionsIntra-Group Transactions are interactions between entities within the same multinational enterprise (MNE). Such transactions form the backbone of related-party dealings and are essential in managing global operations and aligning business objectives across jurisdictions. Understanding intra-group transactions is critical in international tax and transfer pricing, as they directly impact a company's tax obligations, profitability, and compliance standing. Tax professionals, accountants, lawyers,... More.

X BV v Netherlands (Staatssecretaris van Financiën Case) Read More »