The Indian government is rumoured to have changed tack on its structuring of the upcoming advance pricing arrangement (APA) programme. Taxpayers expected a unilateral APA to be incorporated into the Direct Taxes Code in 2012 but officials could be bending to arguments from lobbyists that this way of establishing certainty about transfer pricing would be arbitrary. Sophie Ashley takes a fresh look at the APA process and considers the pros and cons to unilateral and bilateral APAs.
Unlock this content.
The content you are trying to view is exclusive to our subscribers.
As pillar two reshapes global tax competition, the UK faces a crucial challenge: how to remain attractive to multinationals without sacrificing tax revenues
Multinationals importing goods into Brazil may need to align TP files and customs documentation more closely as authorities gain new tools to challenge related-party transactions
The private equity-backed deal hands Grant Thornton immediate and impressive US scale, but World Tax data suggests the firm still has work to do to gain recognition
From Instagram content to £100m transactions, the founder of Thomas & Co International discusses building a modern tax and accounting firm for business founders
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