General Motors case reinforces Indian taxpayers’ right to use foreign entities as tested party

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General Motors case reinforces Indian taxpayers’ right to use foreign entities as tested party

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 Tribunal court overturned a transfer pricing adjustment made against General Motors on these grounds.

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