Shiv Mahalingham (Duff & Phelps) identifies key changes to international transfer pricing guidance, regulations and case law that have occurred in the past few months.
This update sets out a summary of key changes to international transfer pricing guidance regulations and case law that have occurred in the past few months. The major changes relate to judgments in different corners of the world all reaffirming the importance of the economic reality underpinning transactions when assessing international transfer pricing structures.
Indian High Court ruling
On 8 August 2016 in Commissioner of Income Tax v M/s Merck Ltd [2016-LL-0809-53] the Mumbai High Court confirmed some important transfer pricing principles in favour of the pharmaceutical group Merck:
Predatory (i.e. sub-market) pricing as an economic strategy does not in itself render pricing non-arm’s length. (It was also noted that the interaction between domestic transfer pricing and...
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Shiv Mahalingham (Duff & Phelps) identifies key changes to international transfer pricing guidance, regulations and case law that have occurred in the past few months.
This update sets out a summary of key changes to international transfer pricing guidance regulations and case law that have occurred in the past few months. The major changes relate to judgments in different corners of the world all reaffirming the importance of the economic reality underpinning transactions when assessing international transfer pricing structures.
Indian High Court ruling
On 8 August 2016 in Commissioner of Income Tax v M/s Merck Ltd [2016-LL-0809-53] the Mumbai High Court confirmed some important transfer pricing principles in favour of the pharmaceutical group Merck:
Predatory (i.e. sub-market) pricing as an economic strategy does not in itself render pricing non-arm’s length. (It was also noted that the interaction between domestic transfer pricing and...
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If you do not subscribe but are a registered user, please enter your details in the following boxes:
