Avocado Roundup: India Probes Transfer Pricing at Amazon, Apple, Google, Report Says

Avocado Roundup is a quick review of top tax, legal, and climate news stories. It’s written by humans.

  • India’s tax authority has since 2021 been investigating transfer pricing practices of Apple India Pvt Ltd, Amazon Seller Services India Pvt Ltd, and Google India Digital Services Pvt Ltd., on suspicions the US tech giants’ India branches are evading hundreds of millions of dollars in taxes in the country overall, according to a report. The authority has rejected justifications provided by the companies for transactions related to advertising, marketing, promotion expenses, royalty payments, trading, software development, and marketing support services, according to the report, which says Amazon and Apple have hired PwC for help in the case. (Economic Times)
  • After years of negotiations, Pillar 2 on the OECD’s two-pillar international tax reform is set to take effect starting next year with the aim that the world’s biggest companies will have to pay at least 15% in tax on their worldwide income. The outlook for the plan’s Pillar 1, which among other things aims to make sure giant US tech companies pay tax in countries where they have sales revenue, is looking less clear. (The Economist)
  • Diplomats from the European Union and UK are accused of trying to scuttle efforts at the United Nations aimed at giving developing countries more say in global tax negotiations like the ones that created the OECD’s two-pillar plan. (Financial Times)
Gibson Dunn Promotes 35, Including Two Tax Partners
  • Big Law firm Gibson Dunn promoted 35 lawyers to partner, including two tax partners in New York, effective Jan. 1, 2024. (GibsonDunn.com)
  • Big Law firm Bryan Cave Leighton Paisner hired tax lawyer David Holmberg in New York as partner. His practice focuses on private equity real estate, direct lending and distressed strategies. (BCLP.com)
  • FTI Consulting, Inc. announced the appointment of Atlanta-based real estate and tax consultant McRae Thompson as a senior managing director and leader of real estate tax advisory services in the firm’s corporate finance & restructuring segment. Thompson arrives from EY, where he was partner and leader of real estate tax advisory, real estate solutions. FTI Consulting also named senior managing director Stephen Bertonaschi, based in Roseland, New Jersey, leader of real estate tax compliance services. (FTIConsulting.com)
  • Professional services firm RSM Canada hired veteran real estate-focused corporate tax adviser Neil Chander as Toronto-based partner in its international tax practice. He’s had senior roles at Deloitte, PwC, and was in-house at Colliers International and real estate asset and property manager and developer QuadReal Property Group. (Consulting.Ca)
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