The Income Tax Appellate Tribunal (ITAT), Mumbai bench recently delivered an important ruling in the case of Aurionpro Solutions Limited (ASL) on applicability of transfer pricing provisions to business advances granted by Indian parent companies to offshore subsidiaries and related aspects.
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The new guidance is not meant to reflect a substantial change to UK law, but the requirement that tax advice is ‘likely to be correct’ imposes unrealistic expectations
China and a clutch of EU nations have voiced dissent after Estonia shot down the US side-by-side deal; in other news, HMRC has awarded companies contracts to help close the tax gap