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Transfer Pricing

For more transfer pricing news and analysis, please visit ITR’s sister publication, TP Week.

TP Week provides an outstanding and market-leading source of up to the minute information and comment on transfer pricing issues.  So whether you are a tax director in industry, a tax adviser, government representative or transfer pricing specialist, all the intelligence, comment and analysis you need can be found at

  • India advised not to appeal Vodafone ruling

    November 27, 2014

    India’s top lawyer has advised his government not to appeal the Rs 3,200 crore ($525 million) Bombay High Court (HC) transfer pricing decision in favour of Vodafone.

  • G20’s tax evasion concern stymies Australia’s patent box scheme before it starts

    November 26, 2014

    Though base erosion and profit shifting (BEPS) took the front seat during meetings between global leaders on November 15 and 16 at the G20 forum, country leaders also expressed concern over the taxation of intellectual property (IP). Patent box regimes in particular were mentioned as a method used by large corporations to exploit tax incentives.

  • Mitsubishi wins big for Japanese trading companies in Indian Berry ratio transfer pricing case

    November 20, 2014

    Mitsubishi Corporation India’s victory over the Indian tax authorities in the New Delhi Tax Tribunal on the use of the Berry ratio (gross margin divided by operating expenses) sets important precedents for transfer pricing litigation in India, advisers believe, because it legitimises the use of this method for determining profit levels and recognises the importance of business models in transfer pricing decisions.

  • EC says Netherlands tax deal with Starbucks constitutes state aid

    November 14, 2014

    The European Commission has released a preliminary view that an advance agreement struck between Starbucks and the Dutch government constitutes state aid.

  • Argentina suspends P&G operations over allegations of tax fraud

    November 06, 2014

    Procter & Gamble’s (P&G) operations in Argentina have been suspended because of allegations the company overbilled exports to funnel money out of the country, hiding taxable income. Press coverage has intensified and the boundaries between fact and speculation are becoming increasingly unclear.

  • Luxembourg comfort letter tax deals could spell trouble for EC’s Juncker

    November 06, 2014

    The leaking of documents detailing tax arrangements Luxembourg has agreed with hundreds of corporate taxpayers is adding to pressure on Jean-Claude Juncker, president of the European Commission, after last month’s state aid investigation launches into deals signed by the Grand Duchy while Juncker was prime minister had already cast doubt on the appropriateness of his Commission appointment.

  • International Tax Review at 25: What has changed in a quarter of a century

    October 30, 2014

    Tax has changed dramatically since the first issue of International Tax Review came out in November 1989. Using a selection of articles – one from each year – Ralph Cunningham and Matthew Gilleard assess how many of those changes have been reflected in the publication over the past 25 years.

  • France asserts PE in commissionaire structures again

    October 30, 2014

    Eric Meier and Ariane Calloud, of Baker & McKenzie, analyse a recent case about potential permanent establishment of a French entity operating under a commissionaire arrangement with its Swiss principal.

  • Australia’s tax evasion drama: ATO rejects widespread non-compliance as it battles Chevron in court

    October 24, 2014

    Industry and tax professionals have criticised the Tax Justice Network’s methodology in its report that alleges nearly one-third of the largest businesses in Australia are dodging taxes.

  • Bombay High Court rules in favour of Vodafone on share issue

    October 10, 2014

    In a decision that could give relief to more than 20 other pending cases, the Bombay High Court has ruled in favour of Vodafone that in the absence of income, a share issue transaction cannot be subjected to transfer pricing.

International Tax Review Profile

RT @WilliamIanInnes: McKesson v. R. – FCA: Crown response to McKesson motion to file supplementary factum on recusal matter.

Nov 28 2014 11:58 ·  reply ·  retweet ·  favourite
International Tax Review Profile

Jean-Claude Juncker regrets failing to reform Luxembourg tax laws - via @FT

Nov 28 2014 11:15 ·  reply ·  retweet ·  favourite
International Tax Review Profile

Happy weekend to our new followers @gymatthijssen and @CLWain_EY

Nov 28 2014 10:31 ·  reply ·  retweet ·  favourite
International Tax Review Profile

How much will devolving income tax to Scotland yield? via @JolyonMaugham @NicolaSturgeon would do well to read this.

Nov 28 2014 09:18 ·  reply ·  retweet ·  favourite
International Tax Review Profile

EUobserver / Juncker survives confidence vote over #Luxembourg #tax practices. 101-461, with 88 abstentions

Nov 27 2014 05:44 ·  reply ·  retweet ·  favourite
International Correspondents

After the Irish budget, what would make you more likely to put more substance into Ireland?