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TODAY'S ISSUES
Delhi High Court Clarifies Limits of MAP in Transfer Pricing Disputes
Date: 6 February 2025 The Delhi High Court recently ruled in AON Consulting Pvt. Ltd. v. Principal Commissioner of Income Tax on a key...
GTC Global
Jul 141 min read
Polish Court Upholds Arm’s Length Principle in Trademark Licensing Dispute
19 March 2025 The Polish Supreme Administrative Court addressed a dispute involving the tax treatment of trademark royalties received...
GTC Global
Jul 71 min read
Iceland’s First Transfer Pricing Court Case Shifts Burden of Proof
June 2025 In a landmark transfer pricing case, the Reykjavík District Court ruled in favor of the Icelandic tax authority, raising...
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Jun 181 min read
FedEx Ruling Reinforces Limits on IRS Authority in Transfer Pricing Disputes
February 13, 2025 The U.S. District Court for the Western District of Tennessee has ruled in favor of FedEx Corp in a significant...
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Jun 111 min read
Danish Supreme Court Rejects Accenture's Transfer Pricing: Emphasis on Documentation and Economic Substance
9 January 2025 The Danish Supreme Court has upheld the Ministry of Taxation’s assessment in a landmark transfer pricing case involving...
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Jun 41 min read
Mexican GAAR: Economic Substance and Business Purpose Scrutiny
2023 The Mexican Tax Administration Service (SAT) has applied the General Anti-Avoidance Rule (GAAR) in a recent case involving a...
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May 141 min read
Delhi High Court Rules on Service Fees and Profit Attribution to PE in Hyatt Case December 2023
October 16, 2023 The Delhi High Court addressed a dispute involving Hyatt International Southwest Asia Ltd. and the Indian tax...
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May 71 min read
U.S. Tax Court Applies Unspecified Method in Medtronic Transfer Pricing Dispute
August 2022 The U.S. Tax Court ruled on a transfer pricing dispute between Medtronic and the IRS regarding the appropriate method to...
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Apr 281 min read
Czech Supreme Court Confirms Cost Plus Method in Intra-Group Services Case
July 2024 The Czech Supreme Administrative Court ruled on a transfer pricing dispute between BEAS SUN s.r.o. and the tax authorities...
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Apr 71 min read
Dutch Court Upholds Transfer Pricing Adjustment in Agri B.V. Restructuring Case
July 2024 The Dutch Court of Appeal ruled on a transfer pricing dispute between “Agri B.V.” and the tax authorities concerning the...
GTC Global
Mar 311 min read
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