Transfer Pricing Times – August 2019

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In this edition of Transfer Pricing Times, we present the latest and most relevant transfer pricing issues and developments from around the globe.

In the “U.S. Court of Appeals Issues Opinion in Amazon Case” article, we discuss the United States Court of Appeals for the Ninth Circuit (the Court) issuing its opinion in the case of Amazon.com, Inc. & Subsidiaries v. Commission of Internal Revenue, finding in favor of the taxpayer.

In the “French Digital Service Tax Brings France and U.S. to Negotiations” article, we review the agreement between French President Emmanuel Macron and U.S. President Donald Trump regarding the recently enacted three percent digital services tax in France.

In the “Malaysia Earnings Stripping Rules for Restriction on Deductibility of Interest” article, we address the main points of the Inland Revenue Board of Malaysia’s Restriction on Deductibility of Interest Rules which are intended to prevent base erosion through the use of excessive interest expense or any payments which are economically equivalent to interest via controlled financial assistance.

Finally, in the “Further Enhancement of Monetary Limits for Filing of Appeals in India” article, we discuss India’s Ministry of Finance issuing Circular No. 17/2019, which calls for further changes to monetary limits for the filing of appeals by the Department of Revenue in India. 

We hope that you will find this and future issues of Duff & Phelps’ monthly transfer pricing newsletter informative and reliable.


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