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Determining Tax Residency Status

News
September 2, 2024
2min read
The document discusses a case on determining tax residency in the UK. The High Court ruled that C Company, based in Jersey, is not a UK tax resident, providing tax

Pay attention to procedural details when dealing with the tax bureau

News
September 2, 2024
2min read
Howard Baldwin and Karen Baldwin are a couple who own a production company called KEMB.

Issues of Profit Shifting Through Related-Party Transactions

News
September 2, 2024
3min read
The document discusses a profit-shifting dispute involving SKF's French subsidiary due to transfer pricing. The Versailles Court of Appeal sided with the tax authorities and provided compliance advice on transfer

Leveraging Treaty Benefits: Remember the Most-Favored-Nation Clause

News
September 2, 2024
6min read
The document discusses a case where a South African company sought exemption from Dutch withholding tax under the Most-Favored-Nation clause. The Dutch Supreme Court ruled in favor of the company,

Tax Authorities Challenge the Allocation of Subsidiary Shares and Loans to a Permanent Establishment

News
September 2, 2024
4min read
The document discusses the Finnish tax authority's challenge to a foreign company's profit allocation to its permanent establishment. The Finnish Supreme Administrative Court upheld the tax authority's position and provided

Applicability of the Most-Favored-Nation Clause in India’s Tax Treaties

News
September 2, 2024
4min read
The document discusses a transfer pricing dispute between Sony India and the tax authorities. The Indian Income Tax Tribunal ordered a reassessment of the conclusions and provided tax risk management

International transport agency income is not tax-exempt

News
September 2, 2024
4min read
Company A is a tax resident of Singapore and is engaged in international shipping business between India and Singapore. During the 2014-2015 financial year, i.e.

Indian Income Tax Tribunal Orders Reassessment of Transfer Pricing Investigation

News
September 2, 2024
3min read
The document discusses a transfer pricing dispute between Sony India and the tax authorities. The Indian Income Tax Tribunal ordered a reassessment of the conclusions and provided tax risk management

Focus on commercial substance requirements in limitation of interests clauses

News
September 2, 2024
5min read
In 2020, Company A in Country X established a wholly-owned holding company B in Luxembourg as the group's overseas holding platform company, mainly holding subsidiaries in Europe and the Americas.

Considerations for Utilizing the Most-Favored-Nation (MFN) Clause in Tax Treaties

News
September 2, 2024
6min read
The document discusses a tax dispute involving the most-favored-nation clause between Philippines' Company A and U.S. Company B. The Philippine Tax Court partially supported Company A's claims and offered advice

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