France recently enacted transfer pricing provisions detailing penalties taxpayers can incur for noncompliance regarding documentation requirements. A regularisation procedure has also been formally implemented which should reduce the cost of transfer pricing audits.
The Indian government will not appeal the Bombay High Court (HC) ruling which concluded Vodafone was not accountable for a 3,200 crore ($525 million) tax demand.
Mutual agreement procedures (MAPs) and advance pricing agreements (APA) between India and the US hint at closer ties between the two nations and reinforce India’s desire to be seen as an investor friendly country.
The Canada Border Services Agency (CBSA) recently changed its policy on transfer pricing adjustments for customs purposes. The new policy allows eligible importers to seek refunds of custom duties where transfer prices are adjusted downward.
Public comments on BEPS Action 10 welcome the OECD’s simplified approach to dealing with low value-adding intra-group services and generally support the proposed profit mark-up range. However, feedback has stressed the need for clarification over more valuable services and single cost pool allocation has been deemed impractical.
The Income-Tax Appellate Tribunal (ITAT) in Mumbai has ruled in favour of Watson Pharma Private, rejecting India’s views on location savings advantages in favour of the OECD perspective.
