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714 articles

Landmark Transfer Pricing Case: France vs. Willink SAS

Review of the landmark transfer pricing case of France vs. Willink SAS, highlighting the importance of functional analysis, robust…

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India’s Evolving Tax Treaty Landscape

Discover how India tax treaty challenges impact foreign investors and how Dr. Daniel N Erasmus’s expert team can help navigate these…

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Ireland

In-depth Analysis of Ireland’s First Transfer Pricing Case

Discover the critical insights from Ireland’s first transfer pricing case, impacting multinationals and tax authorities worldwide. Learn…

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Understanding the Arm’s Length Principle of Transfer Pricing: A Comprehensive Guide

Explore the arm’s length principle of transfer pricing in-depth with our comprehensive guide tailored for tax professionals and…

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Understanding Management Fees in Transfer Pricing: Key Aspects and Best Practices

Learn about management fees in transfer pricing, including key aspects, challenges, and best practices to ensure compliance with tax…

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United Kingdom

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

Explore the key aspects and implications of the BlackRock HoldCo 5, LLC v HMRC case, focusing on transfer pricing and the unallowable…

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Insights from Italy vs. ING Bank SpA Transfer Pricing Case

Explore critical insights into managing transfer pricing disputes through the Italy vs. ING Bank SpA case, emphasizing compliance and…

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United Kingdom

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

Detailed analysis of the UK vs. Kwik-Fit transfer pricing case, its global implications, and the value of expert guidance in transfer…

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TRANSFER PRICING: INTEREST ON SHAREHOLDER LOANS AND RELATED MATTERS

In this short video, Renier van Rensburg highlights the complexities of transfer pricing interest on shareholder loans and related matters.

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South Africa

WEBINAR: International Tax Planning & Structure Execution

Don’t miss our International Tax Planning & Structure Execution event designed to boost your collaboration skills.

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What is the most common Transfer Pricing Method? The Transactional Net Margin Method Explained

Uncover the essentials of the Transactional Net Margin Method, the most common transfer pricing strategy for global businesses.

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The Three Types of Transfer Pricing

Discover the essentials of transfer pricing methods, key for compliance and optimal business strategy in global markets.

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Join Us at the GTC Conference 2024 in Milan: Mastering Controversy Roadmaps for MNEs

Discover strategies at the GTC Conference 2024 on creating a controversy roadmap for MNEs. Join us in Milan or online on June 7, 2024.

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WORKSHOP: Conducting a Transfer Pricing Trial

Join our free workshop on transfer pricing trials led by Prof Dr Daniel N Erasmus. Gain insights and strategies for managing royalty rate…

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South Africa

Tax Dispute Resolutions: A Case Study on Tresping Manufacturing vs. SARS

Explore the critical insights from the Tresping Manufacturing vs. SARS case on navigating tax disputes and compliance with customs…

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Unpacking the Latest EU Transfer Pricing Updates

Dive into the latest EU Transfer Pricing Updates aimed at harmonizing guidelines within the EU, promising clarity and tax certainty for…

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South Africa

Landmark Transfer Pricing Case from South Africa

TRM Tax Attorneys secures landmark victory in South Africa’s first transfer pricing case, demonstrating expertise in resolving complex tax…

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Netherlands

X BV v Netherlands (Staatssecretaris van Financiën Case)

The X BV v Staatssecretaris van Financiën case revolves around a key issue in corporate tax: the denial of interest deductions for…

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South Africa

South Africa’s First Transfer Pricing Case

Explore how TRM’s expertise in transfer pricing challenges in South Africa helped ABD Limited win against SARS, offering insights for…

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South Africa

South Africa’s first Transfer Pricing case, and it’s a win for the taxpayer!

Can we hear a “woohoo”!? Yes, you read right, South Africa has finally had its first TP case and whaddaya know, the taxpayer won!

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South Africa

ABD Limited vs. SARS Transfer Pricing Dispute Judgment

Explore the critical analysis of the transfer pricing dispute judgment between ABD Limited and SARS, focusing on IP royalties and tax…

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

As Tax/TP practitioners, we are always looking to build synergies across processes, harmonizing our calculation and reporting flows. Aiming…

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South Africa

DID YOU MISS THE MASTERING TAX DISPUTE RESOLUTION IN SOUTH AFRICA WORKSHOP?

This workshop was designed to give aspiring and practising tax professionals an overview of what is needed to navigate the complex terrain…

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Zambia

Understanding Zambian Transfer Pricing: Insights and Compliance Strategies

Explore the intricacies of Zambian Transfer Pricing, including compliance obligations and strategic insights for navigating these…

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