Transfer Pricing Case Laws
AMPOL enters $157 million tax settlement with Australian Tax Office
20 February 2023 Ampol Limited announced entering a $157 million tax settlement agreement with the Australian Tax Office in a dispute over pricing of transactions between Ampol Limited and the ...
OECD publishes Guidance on the Handling of Multilateral MAPs and APAs
1 February 2023 OECD published guidance on Multilateral MAP and APAs. The Manual is intended as a guide to multilateral MAP and APA processes from both a legal and procedural ...
The South African Revenue Service (SARS) issues Arm’s Length Guidance on Intra-Group Loans
17 January 2023 the South African Revenue Service (SARS) released an interpretation note (IN 127) titled “DETERMINATION OF THE TAXABLE INCOME OF CERTAIN PERSONS FROM INTERNATIONAL TRANSACTIONS: INTRA-GROUP LOANS” which ...
Brazil issues Draft Legislation on implementation of the Arm’s Length Principle
28 December 2022 Brazil published draft legislation on implementation of the arm’s length principle as described in the OECD Transfer Pricing Guidelines. The new provisions came into effect on the ...
US Supreme Court denies Whirlpool’s request for judicial review of the 2021 judgement from the Court of Appeal.
21 November 2022 the US Supreme Court denied Whirlpool its request for judicial review of the December 2021 judgement of the Court of Appeal (Sixth Circuit). 10 August 2022 Whirlpool ...
TELE2 announces SEK 1,8 billion victory in Swedish Courts
In a press release dated November 7, 2022, TELE2 announced a SEK 1,8 billion win related to tax deductions for foreign exchange losses on intra-group loans, that had previously been ...
Caterpillar announces $740 million settlement with the IRS
In a press release dated October 27, 2022, Caterpillar announced that a $740 million settlement had been reached with the IRS related to tax issues for FY 2007 through 2016 ...
Credit Suisse enters EUR 238 million settlement agreement in France
A settlement agreement between the French Financial Public Prosecutor and Credit Suisse was announced in the Paris Court of Appeal 24 October 2022. The “CJIP” agreement brings an end to ...
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