Last week’s Vodafone case at the Bombay High Court about the applicability of transfer pricing provisions applied to its transfer of shares with an overseas company was deferred to the Dispute Resolution Panel (DRP) in India.
Last week’s Vodafone case about the applicability of transfer pricing provisions applied to its transfer of shares with an overseas company was deferred to the Dispute Resolution Panel (DRP) in India. The facts of the case so far - and whether an adjustment under transfer pricing regulations should be applied - are now being considered by advisers and their clients.
The OECD hosted a two-day public consultation on transfer pricing in November. One issue up for discussion included country-by-country reporting, with business recognising it will be implemented in some form.
Earlier this year Pierre Collin and Nicolas Colin authored a report, commissioned by the French government, focusing on the taxation of the digital economy. The report focuses on how to measure the taxable profits by jurisdiction for this industry, with recommendations for change, including looking at the definitions of permanent establishment.
Armando Lara Yaffar, chairman of the UN tax committee and the deputy director general for international treaties within the department of revenue and public credit at the Ministry of Finance in Mexico, discusses the development of the UN's practical transfer pricing manual for developing countries.
Next year should see three big transfer pricing litigation cases come to trial in the US: Eaton Corporation, Amazon and Altera. All cases will have a significant impact on taxpayers with possible repercussions on an international scale. Taxpayers need to know what the key issues are and what direction the court is likely to take.
