Lexel AB v Sweden (Skatteverket) – Case C‑484/19
In Lexel AB v Skatteverket (Case C‑484/19), the Court of Justice of the European Union (CJEU) ruled that Swedish tax legislation, which denied Lexel…
Document Category: Transfer Pricing
The untested waters of transfer pricing disputes – Lexology
Tackling base erosion and profit shifting remains a priority for the National Treasury and the South African Revenue Service (“SARS”). It was recently reported that…
Transfer Pricing in Australia: The Roche Case
A decision has been handed down in the Administrative Appeals Tribunal1 that for the first time involves judicial review of a substantive transfer pricing issue…
International Tax Avoidance-The Tension between Protecting the Tax Base and Certainty of Law
In the context of cross border investment , the growing problem of tax avoidance and the use of double tax treaties deserves much greater examination.…
Ford Motor Co of Canada, Ltd. V. Ontario Municipal Employees Retirement Board et al.
The litigation arose from Ford Motor Co.’s successful 1995 effort to take its 94% owned Canadian subsidiary, Ford Motor Co. of Canada (“Ford Canada”), private.…
Eli Lilly & Co. v. Commissioner
Procedural Posture Petitioner parent corporation and its subsidiary challenged respondent Commissioner of Internal Revenue’s (IRS) ruling, which, pursuant to I.R.C. § 482, reallocated gross income…
Digital Permanent Establishment (Digital PE): A road ahead for e-commerce taxation
With nations all over the world raising concerns over tax avoidance due widespread e-commerce transactions, it is essential to analyze the shortcomings in the existing…
Transfer Pricing in Nigeria: The Utility of Advance Pricing Agreements
Olamide Akinla (ADIT) LL.M (Tax) (London) is a Barrister and Solicitor of the Supreme Court of Nigeria
practising in the law firm of Tayo Oyetibo & C…
