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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China and a clutch of EU nations have voiced dissent after Estonia shot down the US side-by-side deal; in other news, HMRC has awarded companies contracts to help close the tax gap