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.
Unlock this content.
The content you are trying to view is exclusive to our subscribers.
But businesses should remain flexible when choosing between internal and external resources to handle added ViDA complexity, ITR’s Indirect Tax forum also heard
The new managing director of R&D tax relief consultancy ForrestBrown tells ITR about his priorities for the business, where he’s focusing his time and what makes tax cool