It is a well known fact that transfer pricing (TP) provisions have fuelled unprecedented litigation in India.TP provisions were introduced in India by the Finance Act, 2001, so as to protect India's right to collect a fair share of tax in respect of ...
In an effort to reduce transfer pricing ('TP') litigation, Section 92CA was introduced by the Finance Act (No. 2), 2009, authorising the Central Board of Direct Taxes (CBDT) to formulate safe harbour rules. By way of the above amendment, CBDT was ...
Revenue authorities have their own targets for tax collection. The targets are often based on the collections made in the earlier year without any regard to the estimated actual profits to be made by the tax payers. The tax officers are so obsessed ...
AP High Court, in the case of Sanofi Pasteur Holding SA, said amendments made in the I-T Act do not nullify India's tax treaties
There are a large number of multinational companies operating in India. In case of multinational companies, it is a common practice that their employees are transferred from one country to other countries for serving offices situated in various ...
Finance Act, 2012, introduced the concept of Advance Pricing Agreements (APA). APAs are common in other developed countries.An Advance Pricing Agreement (APA) is an agreement between the taxpayer and the tax authorities on the pricing of ...
Irrespective of the difficulties, taxpayers have to comply with the transfer pricing regulations and determine the arm's length price
When transfer pricing provisions were introduced in India in the year 2001, no tolerance limit was prescribed for adjustment in arm's length price (ALP). Thus any difference between the ALP, as calculated by adopting an appropriate prescribed ...
The problem of black money in India has reached to a point that the entire political spectrum is committed to bring back the black money illegally stashed outside India. The Government of India is taking serious steps in this direction, including ...
Transfer Pricing (TP) Provisions were introduced in India by the Finance Act, 2001. The TP Provisions were introduced with an intent to protect India's right to collect a fair share of tax in respect of cross-border transactions. In simpler terms, ...
Interest rates in India are quite high compared to the rates prevailing outside of the country
A welcome feature of Finance Bill, 2013, is that it does not contain retrospective amendments and does not seek to overrule pronouncements of Supreme Court. There are only a few proposals in the Budget relating to foreign enterprises. Our ...
The issue for consideration is as to whether the royalty paid by the foreign manufacturers on manufacturing of the goods outside India could also be taxed in India if such goods are sold in India. In terms of section 9(1)(vi)(c), royalty payable by ...
LG Electronics Inc, a Korean company, set up a wholly owned subsidiary in India (LG Electronics India Pvt Ltd). LG Korea provided its technical assistance to LG India for which it agreed to pay royalty at the rate of one per cent. LG Korea also ...
Transfer Pricing (TP) provisions were introduced in India by the Finance Act 2001. The TP provisions were introduced with an intent to protect Indiaâ€™s right to collect a fair share of tax in respect of cross border transactions. In simpler terms, ...