International

The Importance of Pillar One’s Amount B

The recent document on Pillar One’s Amount B offers a critical insight into the evolving landscape of global tax regulations, highlighting its significance for international tax practitioners and academics.

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Exclusive Workshop Invite: Navigating VAT in the Digital Economy

Join us for a critical online workshop, Quo Vadis VAT in a Digitalised World: The Need for Multilateral Coordination, on Wednesday, 28 February, at 14:00 GMT. This complimentary session, led by expert Robert van Brederode, addresses the evolving challenges VAT faces in our digital economy.

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The TPA Transfer Pricing Global Documentation Handbook

The “TPA: Transfer Pricing Global Documentation Handbook – December 2023” is a comprehensive guide for multinational companies navigating the complexities of transfer pricing documentation in compliance with global tax regulations. The handbook emphasizes the importance of consistency across essential documents such as Corporate Income TaxTax returns, Master Files, Local Transfer Pricing Files, Country-by-Country reports, and more, to avoid common pitfalls like inconsistent treatment of intercompany transactions and discrepancies between commercial and tax books.

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BOOK UPDATE: “CONDUCTING A TP TRIAL” – CHAPTER 1 NOW AVAILABLE

Having prepared and argued at numerous Transfer Pricing trials, I thought it a good idea to commit my journey and experiences to paper as a guide to others about to travel this path in a tumultuous world where revenue authorities are looking to maximize their tax collections.

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FREE Online Workshop: Conducting a Transfer Pricing Trial

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

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TRYING TO SETTLE TAX DISPUTES OUTSIDE THE PARAMETERS OF TAX LEGISLATION

This reminds me of a recent issue raised by a client MNE in Africa. The taxpayer was facing a revised tax assessment and had to pay 30% of the revised assessment to advance the matter to tax dispute resolution, i.e. object and then follow the tax dispute resolution process.

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Apple vs. European Commission

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 aid through favourable tax rulings.

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Stora Enso Wood Products vs Czechia

The Supreme Administrative Court (SACC) of the Czech Republic annulled the judgment of the Regional Court in Hradec Králové, which had previously annulled the tax assessment decision of the Odvolací finanční ředitelství against Stora Enso Wood Products Ždírec s.r.o.

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Boston Scientific v. CIT (India): Permanent Establishment and TP Implications

This case, heard by the Indian courts, raises significant issues concerning the activities that constitute a PE, especially in relation to multinational enterprises (MNEs) operating through subsidiaries.

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CEPSA’s Transfer Pricing Case: Spain vs Compañía Española de Petróleos (CEPSA)

The Supreme Court ruled on the tax dispute between the Spanish tax authorities and CEPSA concerning the allocation of general management and administration expenses to CEPSA’s Permanent Establishment (PE) in Algeria.

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