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.
Jeff Soar lifts the lid on WTS UK’s ambitious recruitment plans, the firm's positioning against the big four, and why tax is the perfect profession for AI
Nearly two years after its publication, the Corporate Tax Roadmap is reshaping the UK’s TP framework through incremental reforms focused on scope, transparency and earlier HMRC intervention
The EU agreed new cooperative and investigative measures to tackle VAT fraud, while Hungary faced legal action and Lavez Coutinho expanded its indirect tax team