We are pleased to attach herewith quarterly issue of
“Communique- Your Transfer Pricing Tabloid”.
During the first quarter of 2019, we witnessed Central Board of Direct Taxes (CBDT) continuing with its efforts to project India as an investment-friendly nation, with Bilateral Competent Authority Arrangement, along with an underlying Inter-Governmental Agreement, for exchange of Country-by-Country Reports (CbCR) between India and the USA to reduced CbCR compliance, and also through its Advance Pricing Program (APA) program with the total count reaching 271 APAs till March 2019. On the litigation front, recent time has seen a spate of rulings pertaining to marketing intangibles issue that impacts the way forward on this issue. In the global arena, US and China published their APA reports and Australia released its guidance on inbound distribution arrangements. US Internal Revenue Services (IRS) also published statistics on CbCR, and other countries are aligning their transfer pricing (TP) regulations. Accordingly, towards our objective of being your value-added partners, we discuss the above significant events/ happenings in this quarterly issue as has been tabulated below:
| Topic |
Page No. |
| CbCRs: Recent Update |
2 |
| Vodafone Publishes its CbCR |
2 |
| Marketing Intangibles: The Saga Continues |
2 |
| Other Rulings in India |
4 |
| Indian APA Program Update |
6 |
| US IRS APA Report 2018 |
6 |
| US IRS Publishes Statistics on CbCR |
6 |
| China APA Update |
6 |
| ATO Guidelines – Inbound Distribution Arrangements |
7 |
| Rulings Across the Globe |
7 |
| Other News – Around The Globe! |
8 |
NA_TP Communique_ Quarterly Issue-1
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