Transfer pricing developments continue at intergovernmental level, as well as the country level. A recent French case examines two aspects of transfer pricing: comparability, and business restructuring. In the United States, the IRS has issued a memorandum limiting the ability to offset US tax assessments arising from a transfer pricing adjustments in some cases. An Indian case upholds a taxpayer’s selection of transfer pricing method but gives guidance on how the residual profit split method should be implemented. While the BEPS project continues at OECD, the EU issues transfer pricing related papers and Australia launches its own BEPS project.
