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
Comparable Uncontrolled 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 … Read more
Article 2 – Taxes covered under Double Taxation Avoidance Agreement This Article provides the details of taxes, which would be covered for the purpose of tax Treaty. Any tax which is not provided in Article 2 is outside the purview of the tax Treaty. Article 2 defines the taxes, to which the Treaty shall apply. … Read more
What is International Tax Law? International tax law , in the context of taxation , are the laws, which apply to tax income from activities, that takes place in two or more countries. International tax law, can be found in either of the following : – International Tax Agreements – What are International Tax Agreements … Read more
Foreign Tax credit against MAT or AMT – Rule 128 of Income Tax Rules The concept of double taxation implies that the same income is taxed twice, once in the country of source and thereafter in the country of residence (India in the present case). In order to facilitate free flow of economic resources and … Read more
When making a business acquisition in India, a foreign Investor needs to take a decision on whether it should purchase the shares of the target company, or it should acquire the business as a whole (other modes of acquisition like acquiring assets on a piecemeal basis/through reverse merger into acquirer entity are not covered in this Article). … Read more