CRA Principal, Alberto Pluviano, reviews a report published by the French Ministry of Finance that analyzes the technical issues related to transfer pricing regulation in the French system compared with other countries and proposes new measures that would tighten the French transfer pricing regulations. The report also includes comments regarding permanent establishment issues.
US Tax Court favors unspecified method to determine royalty rate
The first US transfer pricing court decision of 2022 was published on Thursday, August 18, 2022, specifically Medtronic, Inc. and Consolidated Subsidiaries v....