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South Africa

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TP arbitration

  • Arbitration Commission cases soar

    A new report, yet to be published by the European Commission, shows that the number of open cases in the Arbitration Convention (AC) is rising rapidly. The report which has been supplied to TP lists more than 350 cases.  August 07, 2008

  • Arbitration in transfer pricing is increasing

    Arbitration in transfer pricing is growing in importance and is becoming a popular alternative to litigation for tax authorities and taxpayers.  September 22, 2008

  • Arbitration memorandum finds common ground between US and Canada

    Canadian and US tax authorities released a memorandum of understanding (MOU) on November 26 about the mandatory binding arbitration proceedings under the mutual agreement procedure (MAP) of the US-Canada tax treaty. December 07, 2010

  • Canada prepares to implement arbitration

    The US-Canada arbitration provisions represent a turning point in cross-border transfer pricing negotiations between the two trading partners. December 08, 2010

  • Disputes on the rise in Germany

    Werner Stuffer and Susann van der Ham of PricewaterhouseCoopers in Germany discuss the increase of large transfer pricing audits in Germany  August 11, 2009

  • Exclusive: UK dispute system ripe for change

    In a TPWeek roundtable, tax disputes specialists discuss alternative dispute resolution (ADR) and whether there is a place for a formal mediation process in the UK. September 10, 2010

  • Italian Supreme Court rules TP irregularities must be substantiated with clear avoidance behaviour

    In Ruling No. 27296, Italy’s Supreme Court rejected the tax authorities’ appeal against an Italian company’s transfer of goods and services to its German parent. The Supreme Court ruled that if there is no clear economic advantage for a company, simply proving a transaction is not at arm’s-length is insufficient grounds for an adjustment. March 19, 2015

  • Mandatory arbitration gains popularity in advance pricing agreement cases

    A recent memorandum of understanding signed by the US and Germany has introduced a set of guidelines that set out how to utilise arbitration in advance pricing agreements. January 28, 2009

  • Mandatory arbitration makes debut in Canada-US treaty

    Santino Di Libero of Gowling Lafleur Henderson believes the inclusion of mandatory arbitration in the fifth protocol to the Canada-US treaty will help the competent authority process between the two countries October 15, 2008

  • Negotiating Italy’s Arbitration Convention

    Arbitration Convention No. EEC/90/436, approved on July 23 1990, sets forth an arbitration procedure for the settlement of double taxation issues deriving from diverging transfer pricing adjustments applied by associated enterprises in different Member States.  May 13, 2014

  • New states join Arbitration Convention

    Romania and Bulgaria have joined the European Commission's Arbitration Convention. The two EU member states acceded to the process on July 1. July 09, 2008

  • New US model tax treaty continues drive for mandatory arbitration

    The US has released an updated version of its model tax treaty, showing its continued commitment to the use of mandatory arbitration in international disputes. March 03, 2016

  • Pascal Saint-Amans responds to criticism of TP arbitration work

    Pascal Saint-Amans, director for the centre for tax policy and administration at the OECD, has responded to claims the OECD’s work on TP arbitration is moving too slowly. November 20, 2014

  • TP arbitration for developing countries: Benefits and burdens part 1

    The issue of the benefits or otherwise for developing countries of arbitration in tax matters has recently become more pressing. In this three-part series, Michael Lennard, chief of the International Tax Cooperation section of the UN speaks in a personal capacity about some of the issues that may shape transfer pricing arbitration clauses and how they operate in future for taxpayers and their advisers.  October 09, 2013

  • What the US and Canada don’t want you to know about arbitration

    The US and Canadian arbitration provisions were implemented on December 15 2010 but, since then, it is rumoured that only two cases have gone through the process. December 01, 2011