R (on the application of Refinitiv Ltd) v HMRC [2023] UKUT 257
Dated 20 October 2023 In Refinitiv Ltd v HMRC , the UK Upper Tribunal clarified the scope of an Advance Pricing Agreement (APA) in...
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TODAY'S ISSUES
info163016
Oct 231 min read
Judgement of the High Court of South Africa in SARS vs Pather, CASE NO: 52782/21
Dated 6 February 2024 In the case of SARS vs Pather, the High Court of South Africa assessed whether the Commissioner for the South...
GTC Global
Oct 161 min read
Sweden vs “A Loan AB”, January 2024, Supreme Administrative Court, Case No 4068-23
Dated 22 January 2024 The case of A AB , a company within an international group, involved a reorganization plan to acquire shares in B...
GTC Global
Sep 241 min read
Netherlands vs “Tobacco B.V.”, December 2023, North Holland District Court, Case No AWB – 20_4350 (ECLI:NL:RBNHO: 2023:12635)
Dated 15 December 2023 The Dutch company "Tobacco B.V." belonging to an internationally operating tobacco group was subjected to...
GTC Global
Sep 161 min read
Peruvian Supreme Court Overturns Repsol Decision, Establishes New Guidelines for Transfer Pricing Audits
Dated 29 December 2023 The Peruvian Supreme Court, in its ruling dated December 29, 2023, addressed a transfer pricing dispute involving...
GTC Global
Sep 41 min read
Delhi High Court Partially Overturns Tribunal's Ruling on Hyatt's Service Payments and Confirms Permanent Establishment
Dated 22 December 2023 In 1993, Asian Hotels Limited and Hyatt International-Southwest Asia Limited entered into a service agreement,...
GTC Global
Aug 281 min read
Federal Court of Australia Deems PepsiCo Payments as Royalties, Imposing Withholding Tax in Landmark Case
Dated 30 November, 2023 The Federal Court of Australia, in its ruling dated November 30, 2023, addressed a tax dispute involving PepsiCo...
GTC Global
Aug 191 min read
Tax Court of Canada Rejects Blackberry Limited’s Expert Reports on FAPI and FAT Deduction
Dated 12 September, 2023 In a significant ruling, the Tax Court of Canada rejected two expert reports submitted by Blackberry Limited in...
GTC Global
Aug 121 min read
Decision of the US District Court for the District of Colorado, in Liberty Global, Inc. v. United States, Civil Action No. 1:20-cv-03501-RBJ
Dated 31 October, 2023 The US District Court for the District of Colorado has recently ruled that Liberty Global, Inc. (LGI) must...
GTC Global
Feb 152 min read
India - Decision of the High Court of Delhi (India) in Principal Commissioner of Income-tax v. Hellmann Worldwide Logistics India, [2023] 155 taxmann.com 44
Dated 04 October, 2023 In an appeal by the tax department against a decision by the Income Tax Appellate Tribunal (ITAT) regarding the...
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