Finland: Supreme court makes a decision on arm’s length range and TP adjustment
On 13 September 2021, the Finnish Supreme Administrative Court (SAC) published a decision addressing the use of comparable data and the range of results in calculating transfer pricing adjustments. The case concerned a company, Finnish A Oy,
See MoreUS: Tax court issues its opinion in case of Coca-Cola Co. v. Commissioner
On 18 November 2020, the U.S. tax court issued its opinion in a case of Coca-Cola Co. v. Commissioner, 155 T.C. No. 10. The tax court decision upheld two IRS adjustments that had contributed to increasing Coca-Cola’s taxable income by more than
See MoreUS: Supreme Court Will Not Review Ninth Circuit Decision in Altera case
On 22 June 2020 the US Supreme Court announced that it would not review the Ninth Circuit panel decision in the Altera case. The Ninth Circuit decision of 7 June 2019 that upheld the validity of US cost sharing regulations therefore still
See MoreArgentina: AFIP announces draft transfer pricing guidance for public comments
On 2 October 2019, tax authority of Argentina (AFIP) announced a public consultation and posted on the AFIP website a draft resolution concerning transfer pricing compliance procedures. It would replace the existing transfer pricing rules in
See MoreIndia: No international transaction with related party in the absence of an agreement with the AE
Recently, the Mumbai Bench of the Income-tax Appellate Tribunal (the Tribunal) ruled its decision on the transfer pricing (TP) case of Colgate Palmolive (India) Ltd. v. ACIT (ITA No. 6073/Mum/2014 and ITA No. 2778/Mum/2011) in favor of the taxpayer.
See MoreUS: IRS appeals its tax court loss in the amazon transfer pricing case
On 29 September 2017, the Internal Revenue Service filed an appeal against March Tax Court ruling concerning Amazon’s cost-sharing agreement buy-in payment. The case is important because it is expected to provide fundamental guidance on the
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