International Rulings

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

Australian Federal Court upholds inter-company interest on $ 2.5 billion loan as 'excessive'

Australian Federal Court rules against Chevron (an American multinational energy corporation) in multi-million dollars transfer pricing case on inter-company funding, holds interest paid by Chevron Australia to a US affiliate

Nov 02, 2015

US Tax Court invalidates IRS Cost-Sharing Regulations providing for sharing stock-based compensation costs

US Tax Court invalidates part of IRS Cost-Sharing Regulations, 2003 (Final Rule) which provides that taxpayers have to share stock-based compensation costs under cost sharing agreement with AE for services

Aug 03, 2015

US Court: Allows one-time deduction of repatriated cash-dividend, holds backdated receivables not related-party “indebtedness”

US Court reverses disallowance of repatriated cash-dividends to US corporations by taking cognisance of the one-time deduction; Commissioner had disallowed repatriated dividend-deduction based on subsequent year's Closing Agreement which showed

Mar 23, 2015