Transfer Pricing Tax Alerts
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- India releases draft rules on Country-by-Country Reporting and Master File for public consultation.
- Marketing Intangibles – A Different Approach?
- Reimbursement of cost incurred towards “excess capacity” or “infrastructure set up” to be excluded for earning mark-up while determining the arm’s length price.
- Every outstanding “receivables” does not constitute an international transaction.
- Brand usage - not an international transaction
- Technical fee and brand payments - direct nexus with business; AMP is not an international transaction
- APA has a persuasive value for resolving disputes even beyond the rollback years
- AMP activity not an international transaction in case of manufacturers
- Manual Selection Criteria for Tax Scrutiny Announced by CBDT for FY 2015
- CBDT issues clarifications on certain rollback provisions of APA scheme
- ITAT rejected TP adjustment for notional interest on outstanding receivables
- Landmark HC ruling for ALP determination of interest rate on intercompany loan transactions
- CBDT notifies APA rollback rules; APA pre-filing made optional
- High Court overrules bright line test for AMP expenses
- Deloitte India successfully assisted India’s first Bilateral Advance Pricing Agreement
- No separate TP adjustment for Location Savings
- Deloitte India successfully assisted India’s first unilateral APA, along with a Rollback