International Rulings

Canadian Tax Court rejects reassessment inconsistent with MAP-Agreements in Sifto’s TP-case

Tax Court of Canada rules in favor of Sifto Canada Corp (taxpayer), holds that reassessment made by Canadian Revenue Authority (CRA) for taxation year 2004 to 2006 were inconsistent with

May 03, 2017

US Tax Court rules in Amazon’s favor; Rejects ‘perpetual life’ assumption for website technology, marketing intangibles

US Tax Court rules in favor of Amazon US in respect of TP adjustments amounting to $8.3mn and $225mn for 2005 and 2006 made by IRS on account of transfer

Mar 27, 2017

US Tax Court rules in Amazon's favour over TP-dispute on intangibles transfer to Luxembourg subsidiary

US Tax Court rules in favor of Amazon US in respect of transfer pricing adjustments amounting to $8.3mn and $225mn for 2005 and 2006 made by IRS on account of

Mar 24, 2017

45 key takeaways from European Commission's Apple State aid ruling

European Commission (EC) decision in the Apple State aid case concludes that tax rulings of 1991 and 2007 issued by Irish Revenue in favour of 2 Apple sales and marketing/manufacturing

Dec 23, 2016

EC releases Apple state aid ruling

European Commission (EC) releases full ruling in the Apple-Ireland state aid case; On 30 August, 2016, EC ruled that Ireland offered illegal state aid to Apple which enabled it to pay

Dec 20, 2016

US Tax Court : Accepts Columbia Sportswear's TP- study, rejects Department's attempt to recalculate tax base

Indiana (US) Tax Court grants summary judgment in Columbia Sportswear USA Corporation’s (assessee) favour in respect of its purchase of sporting / hiking products from AE for tax years 2005-2007,

Feb 03, 2016

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