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"Marketing intangible" rejoinder continues, Counsels reiterate AMP not a separate transaction
AMP function re-characterization as international transaction impermissible once ALP in order, argues Venkataraman
Read an incisive analysis of transfer pricing cases reported in other countries.
US Tax Court : CUP method most appropriate for ALP of ‘buy-in’ payment of existing intangibles
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Judicial trends on guarantee issue - A debate far from over
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China IRS' increased scrutiny of service fees & royalty payments
Japan says 'tough issues' to increase average MAP processing time : Bloomberg BNA
Watch this space for all the latest APA-related developments!
India signs first bilateral APA with Japan
APA Roll back Rules by year end: Sources