Income Tax : Mauritius is well known as an excellent platform for structuring foreign direct investments into India. Not only does Mauritius be...
Income Tax : What is TNMM Method – TNMM mean Transactional Net Margin Method. It simply state that net profit realized by enterprise from the...
Income Tax : What is high profit – while determine operating profit for the purpose of TNMM, we have to ascertain the profit earned by enterp...
Income Tax : The price charged usually reflects the function that each enterprise performs (taking into account assets used and risk assumed). ...
Income Tax : 1. Loan given to subsidiary company by Holding Indian Company on Interest – it is covered under sec 92 for the purpose of transf...
Income Tax : Vodafone India Services (P) Ltd. Is a wholly owned subsidiary of Vodafone Tele-Services (India) Holdings Ltd., a non resident comp...
Mauritius is well known as an excellent platform for structuring foreign direct investments into India. Not only does Mauritius benefit from a large network of double taxation avoidance agreements (DTAA), such as the India/Mauritius DTAA, it also has sophisticated legislation and regulations crafted with a view to establishing a well regulated and efficient investment funds industry.
What is TNMM Method – TNMM mean Transactional Net Margin Method. It simply state that net profit realized by enterprise from the international transaction with AE should not be less than comparable party having similar transaction. For Example Company a in India having subsidiary at Dubai Company B.
What is high profit – while determine operating profit for the purpose of TNMM, we have to ascertain the profit earned by enterprise for the basis of comparison. Similarly, we have to ascertain the profit of Compare Company for the purpose of comparison. It is also a part of FAR Analysis.
The price charged usually reflects the function that each enterprise performs (taking into account assets used and risk assumed). Comparability analysis of the controlled transaction for the enterprises participating in the controlled transactions provides a basis for characterisation of the controlled transaction to be benchmarked or the characterisation of the tested party Therefore, comparison of the functions
Vodafone India Services (P) Ltd. Is a wholly owned subsidiary of Vodafone Tele-Services (India) Holdings Ltd., a non resident company Mauritian entity. Vodafone Holding is AE (Associate Enterprise) of Vodafone India for the purpose of transfer pricing provisions under chapter X of Income Tax Act 1961. Vodafone india is engaged in providing service in relation to Telecommunication in india.
1. Loan given to subsidiary company by Holding Indian Company on Interest – it is covered under sec 92 for the purpose of transfer pricing adjustment. Interest should be charged at LIBOR i.e. London Inter Bank Offer Rate based CUP Method is bench marking in respect of loan given to its subsidiary/AE as decided in Case Laws.
Problem Faced by Business man as well as Professional :- Stock register as well as details of closing stock in quantitive and rate wise is a major hurdle for both of them. In some business i.e. Labour intensive Work, wholesale and Retail of construction goods releted business, readymade garment business and some other business
CA Ram Bajaj Introduction 1. Section 14A was first inserted by the Finance Act, 2001. However, same was inserted with retrospective effect from 1-4-1962. The inserted section reads as under:— ’14A. Expenditure incurred in relation to income not includible in total income.—For the purposes of computing the total income under this Chapter, no deduction shall […]
CA Ram Bajaj Method of Calculating the Tax liability of VAT in Work Contract:- 1. Exemption Fee Method/Composition Method 2. VAT Method – 1 (Actual labour deduction) 3. VAT Method – 2 (Standard Labour Deduction) Exemption Fee Method /Composition Method – due to complexity of calculation of labour charges and other permissible deduction under vat […]
