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.
There is a shocking discrepancy between professional services firms’ parental leave packages. Those that fail to get with the times risk losing out in the war for talent
They are alleging that leaked tax information ‘unfairly tarnished’ their business operations; in other news, Davis Polk and Eversheds Sutherland made key tax hires
In the first of a two-part series, experts from Khaitan & Co dissect a highly anticipated Indian Supreme Court ruling that marks a decisive shift in India’s international tax jurisprudence
The OECD profile signals Brazil is no longer a jurisdiction where TP can be treated as a mechanical compliance exercise, one expert suggests, though another highlights 'significant concerns'
Libya’s often-overlooked stamp duty can halt payments and freeze contracts, making this quiet tax a decisive hurdle for foreign investors to clear, writes Salaheddin El Busefi
The Clifford Chance and Hyatt cases collectively confirm a fundamental principle of international tax law: permanent establishment is a concept based on physical and territorial presence