Market leading insight for tax experts
View online issue

Quarterly transfer pricing update: Autumn 2016

Speed read

An Indian High Court ruling confirms the importance of the underlying economic fact base when considering the arm’s length principle. The EC’s final decision on fiscal state aid concerning Apple shows it has moved away from transfer pricing and related-party considerations, and towards structural and anti-avoidance considerations, based on the economic reality underlying the transaction. Russia has outlined proposed regulations for country by country reporting and documentation requirements that will take effect from next year. A ruling in Canada illustrates the importance of documenting the rationale for particular corporate structures (including the intended and actual interaction between affiliates). And the IRS releases the final section 385 regulations on the treatment of debt.

If you or your firm subscribes to, please click the login box below:

If you do not subscribe but are a registered user, please enter your details in the following boxes:

Alternatively, you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this article in full.
Please reach out to customer services at +44 (0) 330 161 1234 or '' for further assistance.