Ever since the inception of the transfer pricing (TP) regulations in India, tax authorities have become increasingly vigilant when scrutinising the inter-company transactions and TP policies of multinationals (MNE), resulting in increased intensity of TP audits and a huge quantum of TP adjustments close to $37.21 billion (to date).
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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