October 15, 2015

Vodafone case: Indian indulgence to MNCs when OECD is fighting transfer
We in India have a tough transfer pricing tax code to frustrate the designs of the MNCs but our government subjected to intense pressure from the MNC lobbies has been capitulating. So powerful is the pressure from vested interests that the government …
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Tax Court Decision In Altera Overturns Important Transfer Pricing Regulations
The Altera decision should also support the many taxpayers who have questioned the separate section 482 regulatory requirement that cost-based transfer pricing (e.g., cost-plus pricing for services) must include the cost of stock-based compensation.
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Final OECD Tax Erosion Rules Retain Transfer Pricing Curbs
The group released reports covering 15 areas such as tax treaty abuse and dispute resolution mechanisms, but much of the project focused on transfer pricing practices, or the way businesses charge related companies for goods and services. Transfer …
Read more on Law360 (subscription)