Application of the Doctrine of Unjust Enrichment to Cases of Transfer Pricing Additions Involving the Import of Goods or Services and Cross-Border Loans

Journal
Vyas, P.A.
International
International Transfer Pricing Journal 2012 (Volume 19), No. 3
FormatPDF
EUR
40
| USD
45
(VAT excl.)

This article deals with the issue whether tax authorities under the garb of transfer pricing adjustments are justified in recovering more taxes and duties (taken collectively) from a related-party transaction compared to a similar unrelated-party transaction and suggests measures for the interlinking of values under different taxing statutes.