In 2011 Alta Energy Partners Canada Ltd. (Alta Canada) was a Canadian-incorporated company and fully owned subsidiary of Alta Energy...

The case deals with interest deduction limitation under Section 10 a of the Corporate Income Tax Act of 1969. The issue arose in respect...

Pandox AB, headquartered in Sweden, owns around 157 hotel properties in 15 Northern European countries. As per its transfer pricing...

Medingo Ltd., incorporated in Israel, (developer of a proprietary insulin pump) and its foreign holding company, Roche pharmaceutical...

H. LVAS Sp. z oo, incorporated in Poland, deducted expenses related to intra-group services in its taxable income. The services had been...

A German company acquired shares in a company, which was financed as follows: unsecured subordinated shareholder loan (interest rate 8%);...

In 2006 3M Co entered into a licensing arrangement where certain intangibles were made available to its Brazilian subsidiary. Brazilian...

The Tax Court decided to disregard both the IRS’s and the assessee’s transfer pricing analysis by adopting an unspecified method. As for...

Sacla SA, a French Company, sold a set of brands for EUR 90,000 to its wholly-owned subsidiary in Luxembourg. The French tax authorities...

A large majority of EU Member States’ representatives have expressed their will to move forward with public CbCr. This would require...