EU Study on the Application of Economic Valuation Techniques (2016)

Category: Application of Economic Valuation Techniques within the EU (2016/2017), EU Transfer Pricing Reports | Tag: ,
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  4. US vs. Medtronic Inc. June 2016, US Tax Court
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  5. India vs. Gap International Sourcing Pvt. Ltd., May 2016, ITA No.1077/Del./2016
    Gap International Sourcing was engaged in sourcing products from India to other group companies. The activity comprised of assistance in identification of vendors, provision of assistance to vendors in procurement of apparel, inspection and quality control and coordination with vendors to ensure delivery of goods to group companies. The necessary technical and intellectual basis for provision of these services were provided by the group companies. The Indian company used TNMM to benchmark the service fee...
  6. Germany vs. License GmbH, January 2016, Supreme Tax Court, Case No I R 22 14
    The Supreme Tax Court has held that a parent company cannot be deemed to have earned income from allowing its Polish subsidiary to register locally in the group name. A German business was active in a field of patented technology associated with its own firm name, “B”. It allowed its Polish subsidiaries to register in that name, “B Sp.z.o.o.”, but made an appropriate charge for the use of the technology. It also did not authorise...