Transfer Pricing

Mutual Agreement Procedure Mutual Agreement Procedure (‘MAP’) is a procedure set out in most treaties which permit designated Government representatives to work together to resolve international tax disputes including issues...

Fundamentals of Base Erosion and Profit Shifting - Transfer Pricing Introduction In the past few decades, the world has seen large movement of capital and investment from developed and developing...

Anti-Avoidance measures in certain jurisdictions - Transfer pricing Specific anti-avoidance measures in respect of transactions with persons located in Notified Jurisdictional area was introduced in the Act under sec 94AWe...

Additional reporting by Multinational companies - Transfer pricing The OECD had devised many action plans to combat BEPS. OECD also recommended a three-tier documentation approach for transfer pricing under Action...

Introduction to Transfer Pricing Transfer Price “Transfer Price” is the price at which an enterprise charges for its transaction within its group entitiesInternational transaction involves more than one tax jurisdiction,...

Penalties for non-compliance - Transfer Pricing The Act has prescribed strict penalties for non-compliance in terms of non-disclosure or incorrect disclosure Question International group shall maintain information and documents in...

Income from transaction with Non-Residents – Transfer Pricing Applicability Section 92 is the charging section for Chapter X of the Act. Sec 92 provides that any income arising from an...

Limitation of interest deductions - transfer pricing Introduction Popularly known as ‘Thin Capitalization Rules’, this provision intends to cap the interest that can be paid to the AEs in case...

International Transaction [Section 92B] – Transfer Pricing Transfer pricing provisions are applicable to determine the arm’s length price of international transaction and specified domestic transaction. Though, specified domestic transactions are...

Secondary Adjustment - transfer pricing Introduction As per the OECD’s TP guidelines for Multinational Enterprises and Tax Administrations (OECD TP Guidelines), secondary adjustment may take the form of constructive dividends,...