Secondary Adjustment Transfer Pricing – International Taxation Case Study Gama Ltd., an Indian company, has provided you the following information for year ended 31.3.2019 : – Transaction Related Enterprise Amount as per Invoice (Rs. in crores) Amount as per ITR Purchase of raw-materials Gama , China 200 180 Payment of royalty Gama Pty Singapore 100 … Read more
Whether two Enterprise are Associated Enterprise – Transfer Pricing – Case Study (a) Based on the following data, you are required to ascertain whether Chappel Inc., and Hetal India Private Limited, are Associated Enterprises, in respect of each of these criterion (assume each one of them on a standalone basis): – (b) Which transaction will … Read more
What is a No PE certificate India ? No PE Certificate or No PE Declaration is a certificate given by a non-resident, who is deriving any income from India (which could be interest, Fee for Technical Services, Business Income, etc., ), which enables the Indian payor, to hold tax at a lower rate applicable to … Read more
Applicability of Base Erosion Concepts – Transfer Pricing – Case Study The case of Alpha Inc. was picked for scrutiny assessment u/s 143(2). Given the large number of international transaction, the AO referred the case to the Transfer Pricing Officer to determine the arm’s length price. Keeping in mind the provisions of Base Erosion, you … Read more
Case Study – Transfer Pricing Penalties India Fulcrum India Private Ltd., is an Indian company in which Sunil holds following shareholding : – Nature of Instrument Number Held by Sunil Equity Shares 10,000 2,400 Non-convertible preference shares 50,000 50,000 During financial year 2018-19, Fulcrum India paid a remuneration of Rs. 5 crores to Sunil, who … Read more
When a foreign company invests in India, they have to chose, which instrument should be used to invest. It could be either shares (Equity, Preference, Convertible or Non convertible), Debentures or Loans. Equity Shares, are the most commonly used instrument , by various foreign companies to invest into an Indian Company, or in case of … Read more