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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Ireland’s Department of Finance reported increased income tax, VAT and corporation tax receipts from 2024; in other news, it’s understood that HSBC has agreed to pay the French treasury to settle a tax investigation