Appellate Review of International Tax Cases

Appellate review in international tax may involve distinct issues. This may include the following:

• Interpretation of tax treaties
• Transfer pricing disputes under §482
• Permanent establishment (PE) and the attribution of profits
• Weightage to Foreign Legal Sources when deciding domestic tax laws.

Now that we have understood how appellate review may involve distinct international tax issues.

Next, let’s understand the stages involved in appealing an international tax case.