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.
Unlock this content.
The content you are trying to view is exclusive to our subscribers.
Grant Thornton advanced plans to integrate its Australian firm into its US arm, as tax developments spanned law firm hires, aviation levies and digital services taxes
A new focus on early intervention and increased AI use is transforming how tax authorities are approaching TP audits, though capacity-constrained jurisdictions risk falling behind
The French administration has used AI to detect undeclared swimming pools and verandas but always includes a human in the loop, the AI in Tax Forum heard
India’s Supreme Court rattled cross‑border structuring with its Tiger Global ruling. Subsequent rule changes narrowed the impact, but significant risks around GAAR, substance and treaty access persist