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Corporate Guarantees and Transfer Pricing – The Micro Ink Revolution
1. INTRODUCTION: THE GUARANTEE PRICING CONTROVERSY The Problem That Micro Ink Solved Pre-2016 Scenario: A multinational company (MNC) with Indian subsidiary structure: Parent compa
DRP in Transfer Pricing Assessment: Appellate Rights and Lessons from Vodafone
1. INTRODUCTION: THE DUAL-ROUTE ASSESSMENT MECHANISM The Unique Feature of Transfer Pricing Assessment Unlike ordinary income tax assessments, transfer pricing assessments have a m
Cross-Border Taxation and India’s GAAR: Conflict or Coherence?
Introduction In an era of globalized business operations and sophisticated cross-border tax planning, nations worldwide have been compelled to develop robust anti-avoidance framewo
