India’s Income Tax Appellate Tribunal (ITAT) has delivered a ruling rejecting the tax authority’s attempt to impose a commission-based remuneration model onto GAP International Sourcing, for procurement support services undertaken on behalf of its overseas group companies.
A global trend being driven by taxpayers, revenue authorities and the courts is seeing increasing numbers of transfer pricing disputes being settled earlier and avoiding court hearings, a panel at International Tax Review’s Global Transfer Pricing Forum identified.
Taxpayers were relieved to hear of Nokia’s victory in the Delhi High Court, which confirmed the Indian tax authorities cannot rely on retrospective amendments to the Income Tax Act (ITA) to override double tax avoidance agreements (DTAs).
The European Court of Justice (ECJ) ruled that the UK’s loss relief rules for branches infringe EU law in the Philips Electronics case this month, raising the opportunity for similarly structured groups to bring claims. But the case could have knock-on effects for other taxpayers and open up new lines of attack for taxpayers in future loss relief cases.
Essar Oil will be able to repay the $939 million in sales tax owed to the Indian government in eight quarterly instalments, after a Supreme Court ruling.
The European Court of Justice (ECJ) ruled that Portugal’s exit tax rules are incompatible with EU law last week, and its decision will impact all EU taxpayers, as it broadens the scope of an earlier judgment in National Grid Indus.
