Following the European Court of Justice’s (ECJ) rulings in Meo and Vodafone Portugal, HMRC has recently updated its VAT manual and published a brief...more
On March 23, 2016, the Tennessee Supreme Court issued its much-awaited decision in the case of Vodafone Americas Holdings, Inc. et al. vs. Tennessee Commissioner of Revenue....more
Corporate taxpayers that benefit from cost of performance sourcing face the unwelcome prospect of filing correctly under a state’s statute, yet later learning that a state revenue department is imposing an alternative...more
It is difficult, but not impossible (and quite satisfactory), to find a silver lining for taxpayers in the alternative apportionment opinion Vodafone Americas Holdings Inc. v. Roberts, M2013-00947-COA-R3CV, 2014 WL 2895900...more
India possesses a dynamic and growing economy—one its government portrays as business friendly—and actively encourages continued foreign direct investment. At the same time, aggressive transfer pricing enforcement, including...more