The largest transfer pricing controversy has yet to reach Tax Court. Microsoft has disclosed that it is currently engaged in a long-standing transfer pricing dispute with the IRS over $28.9 billion of ...

Transfer Pricing Regulations Transfer pricing is regulated globally to prevent profit shifting and ensure that multinational ...

Advocate Amardeep Soni & Advocate Harsha Soni Gemplus India Pvt. Ltd. Vs ACIT (ITAT Bangalore) A Case Study of ITAT BANGALORE BENCH ‘A’ ...

In May 2023, Malaysia took a significant step towards fortifying its tax system with the introduction of the Income Tax (Transfer Pricing) Rules 2023 (TP Rules 2023). Amidst a backdrop of other ...

If possible, a transfer pricing document can be presented to show the nature of these transactions. In cases where these transactions are recurring issues during tax audit and the taxpayer has ...

When we hear the term “profit shifting,” we often associate it with cross-border transactions between and among members of multinational companies (MNCs) aimed at reallocating profits across different ...

More than half of FDI firms in Vietnam report continuous losses despite ongoing operations. Experts warn of tax evasion tactics that could distort market competition.

FDI companies in Vietnam are leveraging tax incentives while declaring billions in losses. Experts suggest enhanced tax audits, standardized pricing databases, and global cooperation to curb corporate ...

According to CBDT's circular, the scope of the safe harbour rules has been expanded by increasing the threshold for availing ...

Foreign investors in the Philippines must comply with transfer pricing rules set by the BIR to avoid penalties and audits.

Presently, there are five APA teams in the country with two teams in Delhi and one team each in Mumbai, Bengaluru and Gurgaon ...