On 28 September 2022, the Organisation for Economic Cooperation and Development (OECD) published its Bilateral Advance Pricing Arrangement Manual (BAPAM).[1] The BAPAM aims to help streamline…
In a decision that offers the much-needed certainty in the tax treatment of income arising from the cross-border transfer of rights in intangibles used by Indian subsidiaries of multinational…
Treasury recently released its 2015 Transfer Pricing Advance Pricing Agreements Report to Congress, the seventeenth report since the initial 1999 report. Each year, the Treasury APA Report describes…
