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Issue No. 04 | October 9, 2026 This week’s review focuses on an Indian Tribunal decision concerning a familiar area of transfer pricing controversy: intra-group management and support services, and the tendency of tax authorities to assign a NIL arm’s-length value to such arrangements. The decision does not break new ground, but it reinforces an important distinction. Establishing that services were actually rendered is one question; determining the arm’s-length considera

The principal development in this week’s Global TP Monitor comes from the United Kingdom, where HM Revenue & Customs has substantially expanded its International Manual to explain the practical application of the UK’s reformed transfer pricing framework and the new Unassessed Transfer Pricing Profits (UTPP) regime. The guidance is especially important for financial transactions. It sharpens the distinction between the pricing benefit created by a guarantee and the borrower’

Issue No. 02 | September 25, 2026 India dominates this week’s Global TP Monitor, accounting for all four of the material developments reviewed. The cases span a surprisingly broad section of the transfer pricing landscape—from procedural validity and TPO references to transaction aggregation, comparability, financial transactions and intercompany receivables. For one week at least, the “Global” TP Monitor has a distinctly Indian accent. The decisions are different in subj

Issue No. 01 | September 18th, 2026 Two Karnataka High Court decisions reported this week arrive at essentially the same destination from different directions: one through comparable-company selection and the other through functional characterization. In both cases, the Court declined to disturb fact-intensive transfer pricing findings reached by the Tribunal. The common thread is worth emphasizing. Transfer pricing disputes may begin with methods, margins and comparables, bu

On July 3rd 2019 the Israeli Tax Authority ("ITA") published on their website an updated copy of declaration Form 1385 concerning international transactions conducted between related parties that is to be attached to relevant annual tax return filings as an annex. The updated Form 1385 is relevant for all filings beginning from FY2018. A copy of the updated Form 1385 can be found at the following link: https://taxes.gov.il/TaxesFormsList/itc1385.pdf Further, the ITA publis

Chevron - High Court Appeal The complexity of transfer pricing is again in focus with the taxpayer appealing to the High Court against...

ITA Tax Resolution 6953/16 ITA Tax Resolution 6953/16 was formulated on the grounds that a public company which is a tax resident of a...