In the first case to reference the UN manual since the Indian government formally adopted it, taxpayers can be more confident about using a foreign entity to test whether a transaction is at arm's-length, after the Ahmedabad bench of the Income Tax Appellate Tribunal overturned a transfer pricing adjustment made against General Motors on these grounds.
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Gregor McMillan of Howden explains how insurance-backed financing can help businesses and funds unlock liquidity from tax receivables and other contingent claims
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