Introduction to International Taxation: Key Concepts & Guidelines
International taxation governs the tax framework applicable to cross-border activities of individuals and corporations. It addresses the…
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Global tax coverage
Click a country to read every article we’ve published on it.
Mauritius
Emerging Transfer Pricing Trends in Africa: Insights from Dr. Daniel Erasmus at the 13th Annual…
In this insightful address at the 13th Annual Africa Transfer Pricing Summit, Dr. Daniel N Erasmus explores the most pressing trends in…
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Understanding the Comparable Profit Method (CPM) in Transfer Pricing
The Comparable Profit Method (CPM) is a widely used approach in transfer pricing, employed to ensure that transactions between related…
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Netherlands
Analysis of X BV v Staatssecretaris van Financiën (Case C-585/22): Preventing Tax Fraud Through…
This case focuses on whether the Netherlands’ national tax law, which restricts the deduction of interest paid on intra-group loans in…
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India
Hyatt International vs. India (ADIT)
Hyatt vs India (ADIT) tackles several pivotal issues regarding the attribution of income to a Permanent Establishment (PE) in India, even…
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Ireland
European Commission vs Apple and Ireland (Appeal)
The CJEU’s judgment of 10 September 2024 overturned the General Court’s previous ruling, confirming that Ireland’s tax rulings to Apple…
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What is Comparability Analysis in Transfer Pricing?
Comparability Analysis in Transfer Pricing is a cornerstone of ensuring that transactions between related parties in multinational…
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India
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…
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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…
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Luxembourg
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…
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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…
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Understanding Double Tax Treaties: A Comprehensive Guide
*For clarity, the term Double Tax Treaty (DTT) used in this article has the same meaning as Double Tax Agreement
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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…
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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…
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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…
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South Africa
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…
Read more →The Second Session of the Ad Hoc Committee on the UN Tax Convention
The Second Session of the Ad Hoc Committee on the UN Tax Convention, held from July 29 to August 16, 2024, at the UN Headquarters in New…
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South Africa
13th Annual SAIT Transfer Pricing Summit 2024: Key Topics and Insights
The 13th SAIT (South African Institute for Taxation) Transfer Pricing Summit 2024 is set to be a pivotal event for tax professionals and…
Read more →What is a Permanent Establishment, and How is Its Significance in Transfer Pricing?
A Permanent Establishment (PE) refers to a fixed place of business through which a foreign enterprise conducts business in another country.…
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Italy
The Italian Supreme Court’s Landmark Ruling on Loss-Making Entities: My Take
In August 2024, the Italian Supreme Court delivered a pivotal ruling on transfer pricing, specifically addressing the inclusion of…
Read more →The OECD’s Transfer Pricing Framework for Mineral Pricing
Transfer pricing in the mineral sector is a complex yet crucial aspect of international tax compliance. The OECD has developed a…
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Italy
Italian Supreme Court Ruling on Transfer Pricing: Inclusion of Loss-Making Entities in…
The Italian Supreme Court’s 2024 ruling mandates including loss-making entities in transfer pricing comparability analysis, aligning with…
Read more →Transfer Pricing and Profit Attribution to Permanent Establishments: Insights from Recent Cases
In the increasingly complex landscape of international taxation, Transfer Pricing and Profit Attribution to Permanent Establishments (PEs)…
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Announcement: Online Transfer Pricing Conference Focused on Africa
The Academy of Tax Law is excited to announce an online Transfer Pricing Conference specifically emphasising Africa. This event will
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