Foster’s and the Authority for Advance Rulings: Overview and Commentary
- Shiv Kapoor
- International Transfer Pricing Journal, 2009 (Volume 16), No 1
- 1 January 2009
This article reviews the Foster’s Australia Ltd ruling in India, which considered the taxation of proceeds from the transfer of intellectual property. In addition, the author provides extensive commentary on flaws he perceives in the decision of the Authority for Advance Rulings and proposes a contrasting approach to the issue.