The US Customs and Border Protection (US CBP) published a Notice on May 16 revoking a Headquarters Ruling, HRL 54764 (November 8, 2001). The revocation should make it easier for companies importing products purchased from a related party to navigate the potentially conflicting rules and procedures for complying with US transfer pricing rules, while properly reporting the dutiable value of property imported from a related party.
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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
ITR sat down for a pre-event interview with Tim Zech, WTS Germany, and Jeff Soar, WTS UK, keynote speaker at next week’s ITR AI in Tax Forum 2026 in London
India is signalling flexibility on expat taxation to attract foreign expertise, though employers will need to navigate disclosure, treaty and scope uncertainties