Foster’s and the Authority for Advance Rulings: Overview and Commentary

Journal
Kapoor, S.
International Transfer Pricing Journal 2009 (Volume 16), No. 1
FormatPDF
EUR
40
| USD
45
(VAT excl.)

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.