Arm's Length Principle Vs. Implicit Support: What's the Way Forward?
When applying the UK’s transfer pricing rules to compare an intra-group loan to the hypothetical arm’s length transaction that an independent third-party lender would have agreed to, there is no scope to read in covenants...more
On 21 October 2020, the Full Federal Court of Australia (Logan, Colvin and Thawley JJ) handed down its appeal decision in the case of Victoria Power Networks Pty Ltd v Commissioner of Taxation [2020] FCAFC 169. This case was...more
UK Case Law Developments - Reliance on HMRC's manual statement can, but didn't, give rise to legitimate expectation - In the recent judicial review case of Roao Aozora GMAC Investment Ltd v HMRC, the Court of Appeal...more
On September 24, 2019, the EU General Court (General Court) issued its long-awaited judgments in relation to the appeals brought against two European Commission (EC) decisions of 2015 concluding that tax rulings granted by...more
Deputy Executive Director Greg Matson (a nice guy at heart) announced this week that the Multistate Tax Commission (MTC) has hired its first transfer pricing training consultant and is scheduled to begin training state...more