Mastering Transfer Pricing Litigation: A Strategic Imperative for Multinational Enterprises
With audits increasing 79% in intensity and number (EY 2023), transfer pricing litigation has never been more urgent—or more costly. In fact, 40–5…
Tag: ALP
2025 Transfer Pricing Postgraduate Programmes: A Strategic Investment for MNEs and Revenue Authorities
With global tax landscapes continually evolving, comprehensive training is no longer optional—it is essential.
The Transfer Pricing Postgraduate Pr…
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 …
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…
France vs SAS Roger Vivier: TRANSFER PRICING CASE
The judgment revolves around a tax dispute between SAS Roger Vivier Paris, a distributor of luxury goods, and the French tax authorities. The core iss…
Sweden vs “CA AB”: TRANSFER PRICING CASE
The case at hand concerns a dispute under the Nordic Tax Convention, a treaty aimed at avoiding double taxation among its signatories. The applicant, …
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…
Delhi High Court vs ABIC India Pvt. Ltd: TRANSFER PRICING CASE
The High Court of Delhi, in its judgment dated 14 October 2024, upheld the Tribunal’s decision to reinstate the Transactional Net Margin Method (TNM…
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 …