Tax & Accounting Blog


Japan: Officials Keep Up Transfer Pricing Heat on Taxpayers (except related to the Adobe Japan court decision)

In October 2008, a Japanese court for the first time ruled in favour of a taxpayer in a transfer pricing case. The Tokyo High Court rejected a transfer pricing assessment that had been imposed by the Japanese tax authority on Adobe Systems Co Ltd (the Japanese affiliate of Adobe Systems Inc). The company’s petition had … Read More


Indian Expert Committee Report on the Software Industry: Analyzing the Impact

By Gaurav Shah, MZSK & Associates, Mumbai Gaurav Shah is an associate director with MZSK & Associates, a member firm of the International BDO Network, in Mumbai. Indian captives engaged in software development and software R&D work have long faced transfer pricing challenges, the most important being the margins expected of such captives by the … Read More


Bloomberg BNA Transfer Pricing Forum Examines Treatment of Secret Comparables

By Kevin Bell A survey of practitioners from 26 countries found that nine jurisdictions—Argentina, Australia, Canada, China, Germany, India, Italy, Mexico, and Switzerland—use secret comparables to varying degrees, in violation of Organization for Economic Cooperation and Development transfer pricing guidelines. However, the May survey by Bloomberg BNA’s Transfer Pricing Forum also found that Austria, Belgium, … Read More