General

What is Comparability Analysis in Transfer Pricing?

Comparability Analysis in Transfer Pricing is a cornerstone of ensuring that transactions between related parties in multinational enterprises (MNEs) comply with the arm’s length principle, as defined by the OECD and other international bodies.

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General Motors v. ACIT, Circle International Taxation 1(3)(1), New Delhi

The Income Tax Appellate Tribunal (ITAT), Delhi Bench, ruled in favour of General Motors USA in a case revolving around the Double Taxation Avoidance Agreement (DTAA) between India and the USA. The core issue concerned whether the assessee, an LLC, could be considered a “resident” for tax purposes under Article 4 of the India-USA DTAA

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Understanding the Role of Permanent Establishments in Transfer Pricing

Permanent Establishments (PEs) play a crucial role in the realm of transfer pricing, as they serve as the bridge between international taxation and multinational enterprise (MNE) operations. As global trade becomes increasingly interconnected, understanding how PEs influence transfer pricing has become essential for tax professionals and multinationals alike.

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General Court Judgment in Amazon and Luxembourg v European Commission

The General Court of the European Union ruled in favour of Luxembourg and Amazon, annulling the European Commission’s decision that Luxembourg granted illegal state aid to Amazon through tax rulings.

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Tax Planning in International Taxation: Navigating Compliance and Avoidance

International Tax Planning is a crucial aspect for multinational corporations seeking to optimize their global tax obligations. With the increasing complexity of international tax laws and regulations, tax planning offers a strategic approach to ensure compliance while minimizing tax liabilities.

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Understanding Double Tax Treaties: A Comprehensive Guide

*For clarity, the term Double Tax TreatyA 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

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Mutual Agreement Procedures (MAP): Key Guidelines

Mutual Agreement Procedures (MAP) are key mechanisms that ensure fair tax treatment in international transactions. They help resolve conflicts between tax authorities, avoiding double taxation and promoting business growth.

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Effective Transfer Pricing Dispute Resolution

As global trade increases, so does the complexity of transfer pricing arrangements, leading to potential disputes between multinationals and tax authorities. The significance of transfer pricing dispute resolution lies in its ability to prevent double taxation, ensure compliance with global standards, and mitigate the risk of financial penalties.

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The Critical Role of Business Restructuring in Transfer Pricing

Business restructuring in transfer pricing is a critical topic for multinationals, tax professionals, and revenue services. It involves significant changes in a company’s structure, operations, or both, that can have a profound impact on its transfer pricing policiesTransfer Pricing Policies refer to the rules and methods established by multinational enterprises (MNEs) to determine the pricing

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How Changes in Tax Residency Impact South African Trusts

The impact of tax residency on South African trusts introduces several complexities that require meticulous planning. This guide explores the critical challenges and tax implications associated with changes in tax residency, underlining the need for strategic foresight when managing trusts across different jurisdictions.

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