India vs AON Consulting: TRANSFER PRICING CASE
The High Court of Delhi, in its ruling on AON Consulting Pvt. Ltd. v. Principal Commissioner of Income Tax – 1 and Ors. (ITA 244/2024), addressed a …
Category: Arms Length Principle
Czech Republic vs RR Donnelley Transfer Pricing Case
The case Czech Republic vs. RR Donnelley Czech s.r.o. revolved around a transfer pricing dispute concerning the application of Section 23(7) of the Cz…
Denmark vs Accenture: Transfer Pricing Case
The Danish Supreme Court rendered its decision in the case of Accenture A/S v. Danish Ministry of Taxation, upholding the lower court’s judgment. Th…
Transfer Pricing Challenges with TNMM: Lessons from the SABIC India Case for all Multinationals
The SABIC India case revolves around the rejection of TNMM by the Transfer Pricing Officer (TPO) and the adoption of the residual “other method” u…
Documentation and Burden of Proof: Insights from Transfer Pricing Disputes
In transfer pricing disputes, the quality and comprehensiveness of documentation often determine the outcome. Robust documentation not only serves as …
Comparability Challenges in Transfer Pricing: Lessons from Key Disputes
Comparability data is the cornerstone of transfer pricing compliance, providing the benchmarks necessary to ensure that intercompany transactions adhe…
Economic Substance Over Legal Form: Key Transfer Pricing Challenges and Case Insights
In transfer pricing, the principle of economic substance over legal form has become a cornerstone of tax authority scrutiny and judicial interpretatio…
Aligning with the Arm’s Length Principle: Key Themes and Challenges in Transfer Pricing Disputes
The Arm’s Length Principle (ALP) lies at the core of global transfer pricing rules, designed to ensure that intercompany transactions between relate…