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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Authors from Khaitan & Co evaluate the recent CBDT notification, whereby legacy investments made by investors continue to be exempt from the applicability of GAAR
Geopolitical rivalry is reshaping global tax cooperation, as the OECD’s minimum tax framework fragments and the EU grapples with the ensuing legal fallout
Chile’s revamped GAAR marks a shift toward structural scrutiny, pushing MNEs to strengthen tax governance, economic substance and compliance strategies