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The International Chamber of Commerce (ICC) has criticised jurisdictions that are attempting to tax international transactions that do not take place within their borders.

Freedom of establishment – Free movement of capital – Direct taxation – Income tax legislation − Determination of the taxable income of companies − Companies having a relationship of interdependence − Unusual or gratuitous advantage granted by a resident company to a company established in another member state − Addition of the amount of the advantage in question to the profits of the resident company which granted it − Balanced allocation of the power to tax between member states − Combating tax avoidance − Prevention of abuse − Proportionality.

The Indian Supreme Court has offered some relief to taxpayers by ruling that audits cannot be reopened due to changes in opinions or without tangible new material.

Whether existing methods of resolving transfer pricing disputes are suitable for use in developing countries was the subject of an interesting panel at the UN expert group meeting on transfer pricing.

How the UN transfer pricing manual should tackle documentation requirements was the subject of a spirited panel on the second day of the meeting of experts.

Speakers had much to say about the abuse of the tax rules in less sophisticated jurisdictions during a meeting of a UN transfer pricing group meeting this week.

Income Tax Act; LLC; The Canada United States Income Tax Convention; Canadian sourced income; tax-deferred non recognirition transasction; Internal Revenue Code; US Limited Liability Company;

The Indian Supreme Court has granted a tax holiday to one taxpayer after ruling that the duplication of software from a master copy to a blank disc constitutes a manufacturing process

Countries introduce new taxes on banking industry to recoup losses from government bailouts

The European Court of Justice (ECJ) has found that two UK taxpayers can amend declarations to repay or remit a Customs debt in a case concerning the impact of using an incorrect customs procedure code on customs declarations when goods are being exported from the EU