International Rulings

Australian Federal Court rejects restructuring of Glencore's agreement for copper-concentrate sale between AEs

Federal Court of Australia (Court) allows Glencore Investment’s appeal against TP-adjustment in respect of supply of copper concentrate by its Australian group entity [Cobar Management Pty Ltd (CMPL)] to its

Sep 17, 2019

Swedish Court rules on adoption of full-range, multiple year data for comparability analysis

Swedish Supreme Administrative Court (‘the Court’) rules on adoption of full range of results and use of multiple year data in benchmarking analysis of sale transactions by assessee (Swedish company

Sep 05, 2019

US Appeals Court upholds Tax Court’s relief to Amazon in intangibles related TP dispute

US Court of Appeals (Ninth Circuit) affirms Tax Court’s decision in Amazon, rules that cost sharing buy-in payments made by its European subsidiaries during 2005 & 2006 in exchange for

Aug 19, 2019

US Appeals Court again overturns Altera decision, validates IRS-regulation requiring stock-based compensation costs sharing

Altera Corporation & Subsidiaries vs. Commissioner of Internal RevenueUS Court of Appeals for the Ninth Circuit (in a second decision) again overturns US Tax Court’s invalidation of part of IRS

Jun 11, 2019

Danish SC deletes TP-adjustment on Microsoft Denmark’s marketing activities, holds remuneration at ALP

Danish Supreme Court holds remuneration received by Microsoft Denmark (assessee) for marketing activities in Denmark to be at ALP for tax years 2004-2007; Revenue had made TP-adjustment of DKK 307.5

Mar 01, 2019

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

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

Oct 31, 2018