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CBDT inks Unilateral APA in ITES dealing with severance compensation
OECD releases BEPS discussion drafts on PE profits attribution & transactional profit splits
CBDT notifies rules for computation of interest income pursuant to secondary adjustments
European Parliament passes public CbCR proposal, allows firms to file for exemption
OECD releases country positions on MLI; Mauritius defers signing till June 30

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Special coverage

$ 8.5 bn TP Additions for 7th Audit Cycle: The Inside Story

APAs: Signaling an end to TP litigation?

Marketing Intangibles

Expert
Corner

Safe Harbour Rules for intra-group services - Analyzing the fine-print

Akshay Kenkre (Partner, TransPrice)
Secondary adjustments - Understanding the nuances of interest computation

Akshay Kenkre (Partner, TransPrice)
New Safe Harbour Regime – Impact on outbound financial transactions

Maulik Doshi (Partner, Transfer Pricing, SKP Business Consulting LLP)
Foreign AE as Tested Party – A Test of Patience?

Jitendra Jain (Executive Director, Transfer Pricing, PricewaterhouseCoopers Private Limited)
Secondary adjustment – What lies beneath?

Rakesh Alshi (Partner, Deloitte Haskins & Sells LLP)

Tax
ring

APA Report Card @5 - Dawn of a New Era in TP Litigation?

International Rulings

Canadian Tax Court rejects reassessment inconsistent with MAP-Agreements in Sifto’s TP-case

Domestic TP

Navigate through the nuances of Domestic-TP legislation

Transfer pricing officers to carry domestic TP-audit, clarifies CBDT

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