International Rulings

Canadian Federal Court rejects Revenue’s oral-interview request of company personnel during TP-audit

Federal Court of Canada (‘the Court’) rejects Minister of National Revenue’s (‘Minister’) application to compel Cameco Corporation (‘Cameco’) to produce approximately 25 of its personnel (including CEO/ CFO etc.) for oral

Aug 29, 2017

US Tax Court holds cancellation of APAs by IRS as abuse of discretion

US tax Court holds that cancellation of APAs (entered with Eaton Corporation and Subsidiaries, ‘taxpayer’) by IRS was an abuse of discretion; Notes that IRS had entered into APA I

Aug 04, 2017

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

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