International - Application of the Doctrine of Unjust Enrichment to Cases of Transfer Pricing Additions Involving the Import of Goods or Services and Cross-Border Loans
- P.A. Vyas
- International Transfer Pricing Journal, 2012 (Volume 19), No 3
- 23 April 2012
This article deals with the issue whether tax authorities under the garb of transfer pricing adjustments are justified in recovering more taxes and duties (taken collectively) from a related-party transaction compared to a similar unrelated-party transaction and suggests measures for the interlinking of values under different taxing statutes.