The Spanish Supreme Court has made a decision on permanent establishment which not only contrasts with that of France’s Zimmer case and Norway’s Dell case but means taxpayers should re-examine structures where a Spanish company performs activities for non-resident related entities under contract.
Taxpayers are preparing higher proportions of their own transfer pricing documentation before handing over to their advisers but certain important factors are being overlooked.
Since the UN embarked upon its transfer pricing guidelines for developing countries, the OECD has been condemned for the work it is also doing in this field by non-government organisations (NGO). The OECD’s Marlies de Ruiter explains why that criticism is short-sighted.
When it comes to dealing with the tax authorities in India, transfer pricing practitioners are making rookie mistakes that delay the process, to the detriment of their clients, according to one official.
Pepsi Foods’ stay of application with the Indian legal system over a demand of Rs1.04 billion ($21 million) has been disposed by the Income Tax Appellate Tribunal (ITAT) but an appeal date has been set.
