India
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
India is signalling flexibility on expat taxation to attract foreign expertise, though employers will need to navigate disclosure, treaty and scope uncertainties
Booming APA statistics reflect the growing credibility of India’s TP framework and the country’s shift toward a tax certainty approach, ITR has heard
Authors from Khaitan & Co evaluate the recent CBDT notification, whereby legacy investments made by investors continue to be exempt from the applicability of GAAR
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Sponsored by Deloitte Transfer Pricing GlobalDeloitte’s practitioners from across the globe report on four of the most prominent transfer pricing (TP) controversy cases from the recent past: Adecco (Denmark), Glencore (Australia), Cameco (Canada), and Philips (France). -
Sponsored by Deloitte Transfer Pricing GlobalEddie Morris, Jennifer Breeze and Janelle Sadri discuss how the growth in the number of mutual agreement procedures, coupled with fine-tuning of the process, has affected its themes of access, resolution and implementation.
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Sponsored by Deloitte Transfer Pricing GlobalEric Lesprit, Mariusz Każuch and Howard Osawa look at three national case studies and consider whether the increased use of international data improves cooperation among tax administrations.
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