From the Controversy Landscape – Code of Conduct Principles of Tax Authorities vs Tax Payers…
GTC Conference 2022 The introduction of BEPS has changed the landscape of international taxation. It brought about not only legislative
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Global tax coverage
Click a country to read every article we’ve published on it.
France
Ferragamo France Transfer Pricing Case: Key Lessons for Luxury Brands
The Ferragamo France transfer pricing case offers valuable insights for luxury goods companies. This landmark ruling highlights the…
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India
UPS Asia Group Pte. Ltd. Case: Transfer Pricing and Permanent EstablishmentUPS Asia Group Pte.…
The case of UPS Asia Group Pte. Ltd. vs. Asstt. Commissioner of Income Tax revolves around the interpretation of whether the applicant had…
Read more →GE Energy v. CIR (Netherlands): Impact of the Libyan Subsidiary on PE Determination
In the case of GE Energy v. CIR (Netherlands), the Dutch Court of Appeal delivered a crucial judgment involving the determination of a…
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Denmark vs EAC: Lessons in Transfer Pricing and Currency Restrictions for Multinational…
DOWNLOAD THE FULL SUMMARY IN PDF HERE VIEW THE FULL JUDGMENT HERE Case Information Court: Østre Landsret Case No: BS-12642/2020
Read more →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
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Australia
Transfer Pricing Dispute Between Australia and Glencore Investment Pty Ltd
Glencore Australia (CMPL) sold copper concentrate produced in Australia to its Swiss parent, Glencore International AG (GIAG). The tax…
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United States
Coca-Cola vs. IRS: Landmark Transfer Pricing Dispute
The Coca-Cola transfer pricing dispute is a landmark case between The Coca-Cola Company (TCCC) and the Internal Revenue Service (IRS). The…
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Canada
Canada (Her Majesty the Queen) v. Cameco Corporation
The Federal Court of Appeal’s ruling in the case between Her Majesty The Queen and Cameco Corporation centers on the application of…
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Zambia
Mopani Copper Mines PLC v. Zambia Revenue Authority
The Supreme Court of Zambia ruled on the appeal by Mopani Copper Mines PLC against the Zambia Revenue Authority (ZRA) regarding tax…
Read more →Transfer Pricing Masterclass
Article by: Quebiko.com Now you are able to take the most inclusive Transfer Pricing courses at great pricing on either
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Nigeria
Transfer pricing in a nutshell: Nigeria
Article by: Udo Udoma & Belo-Osagie Overview Prior to 2012, there was no comprehensive law regulating transfer pricing in Nigeria.
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South Africa
SARS is circulating a section 46 of the Tax Administration Act, 2011 request for relevant…
Article by: Dr Daniel N Erasmus (Pieterse TRM Erasmus Tax Attorneys) SARS is circulating a section 46 of the Tax
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Greece
Transfer pricing methods in Greece
Article by: Fotodotis Malamas (Bernitsas Law) Accepted methods What transfer pricing methods are acceptable? What are the pros and cons
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Israel
Transfer pricing in a nutshell: Israel
Article by: Eyal Bar-Zvi (Herzog Fox & Neeman) Overview Israel’s transfer pricing regime is regulated under Section 85A (Section 85A)
Read more →Transfer Pricing Guidance on Financial Transactions
INCLUSIVE FRAMEWORK ON BEPS: ACTIONS 4, 8-10 Paper by: OECD Please download document here:
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South Africa
SARS will now use artificial intelligence to make ‘it hard and costly’ to dodge tax
Article by: James de Villiers Sars said it would, therefore, hire several executives in data-driven positions to harness the advances
Read more →A MODEL OF TAXPAYERS’ RIGHTS AS A GUIDE TO BEST PRACTICE IN TAX ADMINISTRATION
Paper by: Duncan Bentley In 2003, Messere, De Kam and Heady identified major trends in taxation and benefits during the
Read more →Here Are 10 Geo-Political Economic Trends To Watch
Paper by: George Mentz 1. Energy Independence Innovation – Technology has made finding and harvesting oil and gas much more
Read more →Timeless principles of taxpayer protection: how they adapt to digital disruption
Paper by: Duncan Bentley This article analyses the impact of digitalisation on the tax administration, with a focus on taxpayer
Read more →OECD tax proposal gathers pace, but many unanswered questions
Published by Lexology Article by: Macfarlanes LLP – Rhiannon Kinghall Were Last week (9 December) the OECD held a public consultation on
Read more →The OECD opens a public consultation for its proposals on digitalisation of the economy under…
Published by Lexology Article by: Osborne Clarke – Daniel Rioperez and Ana Malagon On November 8, 2019, the OECD published for public…
Read more →Tax litigation in USA
Published by Lexology. Article by: Steptoe & Johnson LLP – Carina C. Federico, J. Walker Johnson and Robert J. Kovacev Competent courts…
Read more →Tax treaties in Sub-Saharan Africa: A critical review
Paper by: Martin Hearson There is growing attention on the question of tax treaties signed by developing countries. The costs
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