UK Upper Tribunal: Confirms TP-applicability on Bonus Share issue to AE; Distinguishes Vodafone India ruling

Oct 31,2018

UK Upper Tribunal confirms applicability of TP provisions to the issue of bonus shares to 100% holding company; Refers to Para 7.6 of OECD Guidelines and clarifies that an issue of shares by a subsidiary to its parent company  “amounts to an activity which provides economic or commercial value to the parent company or enhances its financial position such that an independent enterprise would be willing to pay for the share issue”


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