Google India is appealing a court decision that found payments made to Google Ireland should be classified as royalties. Digital companies operating in India fear the negative impact from the decision that could trigger double taxation under India’s equalisation levy.
The EU’s proposal for taxing the digital economy isn’t sitting well with American businesses. Bill Sample, former VP of tax at Microsoft and chair of the US Council for International Business, tells TP Week why the EU’s focus on profit split concerns him and what it could mean for impacted businesses.
The Court of Justice of the European Union decided in the Hornbach-Baumarkt case that deviations from the arm’s-length principle can be permissible in certain circumstances. The ruling is expected to have a significant impact on cross-border transfer pricing adjustments.
An OECD discussion draft on intra-group financial transactions is slated for release in July. Stakeholders hope the OECD can provide some much-needed principles on financial transactions such as intra-group guarantees to avoid differences between countries that lead to transfer pricing controversy.
