The IRS has released its advance pricing agreement (APA) programme statistics for last year and the figures suggest taxpayers are losing patience and faith in the system.
The Delhi High Court has ruled that the transfer pricing officer (TPO) cannot disallow royalties just because the company paying them is incurring losses.
Taiwan’s Supreme Administrative Court has issued a ruling in a transfer pricing case for the first time. The litigation, which focused on adjustments, went in favour of the tax authorities.
The Canadian government has proposed changes to section 247 of the Income Tax Act in relation to transactions with foreign related parties, which could have a knock-on effect on companies’ structures involving withholding tax.
Is the arm’s-length principle enough? The short answer is not quite, but when you put multinational companies, tax campaigners, OECD officials and economists in the same room, there is never a short answer.
