McKesson has filed a supplementary memorandum of fact and law after the Court of Appeal deemed its initial memorandum too lengthy. The controversial transfer pricing case, involving a trial judge’s recusal, appears unlikely to come to a conclusion anytime soon.
The Central Board of Direct Taxes (CBDT) in India has introduced a new dispute resolution framework in an attempt to bring greater neutrality to tax dispute resolution and encourage multinationals to do more business in the country.
On December 10 the Luxembourg Ministry of Finance released proposals relating to tax transparency and advance rulings. This move comes as no surprise in the light of the recent “Lux leaks” scandal and appears to be a strategic attempt at advertising Luxembourg’s willingness to fight tax evasion.
Action 8 of the OECD’s BEPS project on the transfer pricing aspects of intangibles aims to achieve universal consensus over definition. However, this is beginning to look like an impossible task, with influential BRIC countries such as India, making their own interpretations.
The risks versus people functions debate has long been a bone of contention in the tax world. The OECD’s BEPS project has signalled a drastic shift towards people functions, which means taxpayers and tax authorities will have to rethink value chain management.
