A ruling by the Spanish Central Economic-Administrative Court (TEAC) against computer technology company Dell has narrowed the possibility for groups operating in Spain to declare they have no permanent establishment (PE) there.
In the latest US court ruling in a debt-versus-equity case, the 100-page judgment in the litigation concerning soft drinks company PepsiCo could help indicate the “super factor” in characterising a structure.
The South African Supreme Court of Appeal rejected the taxpayer’s and South African Revenue Service’s (SARS) arguments in its Armgold judgment this week, where it addressed the deduction of mining capital expenditure for taxpayers operating multiple mines.
Australian iron ore company Fortescue Metals was granted leave by the High Court yesterday, to clarify the case it wants to bring against the government over the Minerals Resource Rent Tax (MRRT).
Taxpayers, revenue authorities and the courts are seeing increasing numbers of transfer pricing disputes being settled earlier, avoiding court hearings, a panel at International Tax Review’s Global Transfer Pricing Forum identified.
