Transactional Net Margin Method The application of Arm’s Length Principle while implementing the provisions of Transfer Pricing, to arrive at the price of a transaction between unrelated parties is essential. However different situations call for application of different methods of the ALP principle, depending on the mitigating factors in every transaction. One such method is … Read more
Profit Split Method Transfer Pricing The application of Arm’s Length Principle while implementing the provisions of Transfer Pricing, to arrive at the price of a transaction between unrelated parties is essential. However different situations call for application of different methods of the ALP principle, depending on the mitigating factors in every transaction. One such method … Read more
Cost Plus Method Transfer Pricing The application of Arm’s Length Principle while implementing the provisions of Transfer Pricing, to arrive at the price of a transaction between unrelated parties is essential. However different situations call for application of different methods of the ALP principle, depending on the mitigating factors in every transaction. One such method … Read more
Resale Price Method Transfer Pricing The application of Arm’s Length Principle while implementing the provisions of Transfer Pricing, to arrive at the price of a transaction between unrelated parties is essential. However different situations call for application of different methods of the ALP principle, depending on the mitigating factors in every transaction. One such method … Read more
Functions, Assets and Risk Analysis Another method that can be used for calculating the transfer price in an international transaction between Associated Enterprises is the Functions, Assets and Risk Analysis Method. It is quite broad and dynamic since it takes into account the various business models (functions, assets and risks) of an enterprise involved in … Read more
Country by Country Reporting (CbCR) Transfer Pricing Generally, the group structure of a MNC would be as under : – Ultimate Parent company, say in USA; Regional Holding companies – Say one for Asia (Regional Holding company 1) which is a subsidiary of the US company and owns all the companies in Asia, one for … Read more
Specified Domestic Transaction under Transfer Pricing – Section 92ba of Income tax act Transfer Pricing on Income From Domestic Related Party Transactions – [Section 92(2A)] Specified Domestic Transactions were covered under transfer pricing regime to – Determine income from domestic related party transactions ; and Determine reasonableness of expenditure between domestic related parties. Section 92(2A) … Read more