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.
Pillar two compliance is creating unprecedented data demands for multinational tax departments, making closer collaboration with FP&A teams essential for accurate reporting and audit readiness
ITR's podcast examines whether the big four have overarching cultural issues and assesses the competitive threat of technology-backed transfer pricing firms
From Mauritius substance rules to Kenyan SEP tax and South African anti-avoidance measures, businesses must navigate growing scrutiny of cross-border IP structures in Africa
ITR spoke to multinationals, advisers and software providers about a June 30 deadline defined by faulty portals, high compliance costs and hard lessons
Tax advisers should revisit India secondment arrangements after the EY US ruling strengthened the Centrica precedent and raised fresh withholding concerns