Foster’s and the Authority for Advance Rulings: Overview and Commentary
Journal
International Transfer Pricing Journal 2009 (Volume 16), No. 1
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.