Europe Archives - Page 4 of 6 - Academy of Tax Law

Analysis of the Transfer Pricing Case: France vs. SAP France

Dispute Resolution, France, International Tax, Tax Dispute Resolution, TP Case Summaries, Transfer Pricing / Dr Daniel N Erasmus

Detailed analysis of the France vs. SAP France 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, its implications for multinationals, and preventative measures for better tax management.

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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.

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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.

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Analysis of BlackRock HoldCo 5, LLC v HMRC: Transfer Pricing and Unallowable Purpose Test

Europe, International, International Tax, TP Case Summaries, Transfer Pricing, United Kingdom / Dr Daniel N Erasmus

Explore the key aspects and implications of the BlackRock HoldCo 5, LLC v HMRC case, focusing 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 and the unallowable purpose test.

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UK vs. Kwik-Fit Transfer Pricing Case: Implications for Multinationals

International, International Tax, Transfer Pricing, United Kingdom / Dr Daniel N Erasmus

Detailed analysis of the UK vs. Kwik-Fit 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, its global implications, and the value of expert guidance 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 matters.

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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.

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The Journey of a Single Data Point: Cross-Process TP Automation in Workiva

Africa, Europe, International, International Tax, Transfer Pricing / Dr Daniel N Erasmus

As Tax/TP practitioners, we are always looking to build synergies across processes, harmonizing our calculation and reporting flows. Aiming to create a “Single Source of Truth” solution for all our Tax/TP needs. We all feel and understand the pressure we are under to comply with the ever-increasing tax reporting burden. Fragmented, over-engineered, do we need to say more!

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FREE Online Workshop: Conducting a Transfer Pricing Trial

Africa, Europe, International, Transfer Pricing / Dr Daniel N Erasmus

Learn how to best Conduct a 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 Trial with leading experts Prof. Dr. Daniel N Erasmus and Mr. Renier van Rensburg from Middlesex University and IITF.

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EU Tax Law

Europe / Dr Daniel N Erasmus

Dr. Erasmus, with his expertise in tax law, can provide valuable guidance on navigating the complexities of EU tax regulationsTax 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, helping businesses comply with the law while optimizing their tax positions.

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Apple vs. European Commission

Arms Length Principle, EU, International, International Tax, Ireland, Postgraduate Programmes in International Tax, Postgraduate Programmes in Transfer Pricing, TP Case Summaries, Transfer Pricing / Dr Daniel N Erasmus

This case revolves around the European Commission’s appeal against the General Court’s decision to annul the Commission’s ruling that Ireland granted Apple unlawful state aidState Aid refers to financial assistance provided by public bodies, typically governments, which can selectively benefit certain businesses or industries. This concept is critical in European Union (EU) law, where such support can distort competition and trade within the single market. State Aid, regulated under EU law, aims to ensure fair competition and prevent Member States from favouring local businesses... More through favourable tax rulingsA tax ruling is a formal decision provided by a tax authority, clarifying how specific tax laws and regulations apply to an individual taxpayer or a corporate entity in particular circumstances. Often sought before a significant financial transaction or investment, tax rulings offer legal certainty by outlining the tax implications and obligations in advance. Such rulings are pivotal for multinational... More.

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