Transfer pricing cases in India are estimated to account for more than half of the world’s transfer pricing disputes. Prolonged transfer pricing litigation due to overburdened courts and tribunals is…
Intertax issue 12 is available and I am delighted to share with the reader the topics dealt with in the issue.
In my editorial, “Taxes and Competiveness: How Much Competitive Is European Tax…
On 30 August 2018 the OECD released the fourth round of BEPS Action 14 peer review reports on improving tax dispute resolution mechanisms. Included in this round was a report on Australia. The report…
I am delighted to share the contents of Intertax issue 11 with our readers.
My editorial entitled “Profit Splitting and the Aspirational Arm’s Length Principle” discusses the (in)adequacy of the arm’…
Following three years of investigation, McDonald’s has been cleared from the charge that it received fiscal state aid from Luxembourg, by virtue of the European Commission’s concluding decision of 19…
VAT is a broad-based tax on final consumption by households. Even if, due to the invoice-credit mechanism through which the tax is normally levied, only final consumption is ultimately targeted, VAT…
By now, warranty & indemnity (W&I) insurance is more or less a transaction solution commodity. As such, it clearly has entered its next product life-cycle phase. Expectations are that stand-…
Almost every foreign client I have advised has at some stage told me how complex the Indian Income Tax Act is. And those who follow Indian tax jurisprudence closely know that judicial decisions, in…
If the BEPS Project is considered formally concluded with the signature of the Multilateral Instrument, the war against base erosion and aggressive tax planning is still ongoing, with many battles…
It is common to face resistance in MAP application, which is essentially based on misconception of Double Taxation Conventions (DTCs). As Article 9(1) establishes the arm’s length standard, which…
