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.
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DLA Piper’s co-head of tax for the US and Latin America tells ITR about her fervent belief in equal access to the law, loving yoga, and paternal inspirations
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