Transfer Pricing Adjustment on Issuance of Shares to Overseas Parents Leaves Companies Shell-Shocked

Journal
Krishnamurthy, V.
India
International Transfer Pricing Journal 2013 (Volume 20), No. 5
FormatPDF
EUR
40
| USD
45
(VAT excl.)

The author considers the latest transfer pricing controversy to originate from India, namely the attempt by the tax authorities to tax the discount on shares issued to a foreign parent company, as well as the assertions made by taxpayers and the tax authorities to defend their positions.