Transfer Pricing

Transfer Pricing & GST

Income Tax - The Goods and Services Tax (GST) is being introduced in the country after 13 year long journey since it was first discussed in report by Kelkar Task Force on indirect taxes. Agreeably, one could count GST as country’s biggest tax reform which can trigger transformation on how businesses works across all industries and overhaul India’s...

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Accounts Receivable Overdue Not Subject to Transfer Pricing

Income Tax - It can be fairly concluded from the above judicial pronouncements that the receivable mentioned in the Explanation to Sec.92B can be taken up for transfer pricing scrutiny only when it is a standalone activity or a demonstrated approach is adopted by the assessee to use Accounts Receivable to have free working capital funding....

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Country-by-Country Reporting & Furnishing of Master File (Transfer Pricing)- Latest Developments

Income Tax - The Central Board of Direct Taxes (CBDT), on 31st October, 2017, has notified the final set of Rules for Maintaining and Furnishing of Transfer Pricing Documentation under Income Tax Rules 1962. Objective: To introduce provisions for additional TP documentation and Country – by – Country reporting to implement the recommendatio...

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Indirect transfers – Deciphering global perspective v. India’s outlook

Income Tax - After the recent worldwide implementation of OECD’s recommendations to prevent Base Erosion and Profit Shifting (BEPS), another forum (The Platform for Collaboration on Tax) has released a discussion draft on The Taxation of Offshore Indirect Transfers – A toolkit (hereafter, referred as the toolkit) for public comments on 1 August, 2...

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Are Safe Harbor margins attractive?

Income Tax - Under Transfer Pricing regulation, Safe Harbor rules means binding rules laid down under law which mandates income tax authorities to accept the transfer price declared by the assesse, if opted for. Further section 92CB provides methods for determination of arm’s length price....

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Guidance Note on Transfer Pricing Report U/s. 92E of Income Tax Act, 1961

Income Tax - ICAI has released the 6th Edition (November 2017) of the Guidance Note on Report Under Section 92E of the Income Tax Act, 1961 (Transfer Pricing). This Guidance Note was previously revised in February, 2013 , August 2013 and October 2016. The ICAI has revised Guidance note on Report under Section 92E of the Income Tax […]...

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Fighting Tax Crime: The Ten Global Principles

Income Tax - This report sets out the 10 essential principles for effectively fighting tax crimes. It covers the legal, institutional, administrative, and operational aspects necessary for putting in place an efficient system for fighting tax crimes and other financial crimes. It draws on the insights and experience of jurisdictions around the world. ...

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Effective Inter-Agency Co-Operation in Fighting Tax Crimes and Other Financial Crimes (Third Edition)

Income Tax - This report describes the current position in 51 countries as to the law and practice for domestic inter-agency co-operation in fighting tax crimes and other financial crimes including, for the first time, co-operation with authorities responsible for the investigation and prosecution of corruption. It identifies successful practices base...

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Tax Inspectors Without Borders – Bolstering domestic revenue collection through improved tax audit capacities

Income Tax - International tax experts gathered today at the OECD in Paris to share experiences and identify best practices in the implementation of Tax Inspectors Without Borders (TIWB) programmes....

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OECD updates transfer pricing country profiles reflecting transfer pricing legislation and practices

Income Tax - The OECD has published updated versions of transfer pricing country profiles (TPCP), reflecting the current transfer pricing legislation and practices of 31 participating countries. The country profiles contain up-to-date and harmonised information on key aspects of transfer pricing legislation, provided by countries themselves....

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Company with different risk profile / Size cannot be comparable despite similar functional profile

CIT Vs Ut Starcom Inc. (India Branch) (Delhi High Court) - CIT Vs Ut Starcom Inc. (India Branch) (Delhi High Court)- When we examine the profile of the assessee company vis-à-vis Infosys Technologies Limited in the light of the judgment in CIT vs. Agnity India Technologies Pvt. Ltd. (supra), there is no comparability for benchmarking the international tran...

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Broad functionality not sufficient to find comparable entity unless similarity with controlled transaction

Avenue Asia Advisors Pvt. Limited Vs. DCIT (Delhi High Court) - Avenue Asia Advisors Pvt. Limited Vs. DCIT (Delhi High Court) Broadly, it appears that the ITAT has gone on the usage of several terms such as debt syndication, debt financing, IPO advisory, corporate restructuring, mergers, acquisitions etc, appearing in the annual reports of the comparable to hold...

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Company with extraordinary events cannot be considered as comparable

Cummins Turbo Technologies Ltd. Vs DCIT (ITAT Pune) - ITAT held that on account of extra ordinary events viz. acquisition of IQ group of companies and amalgamation of Accentia Infoserve Pvt. Ltd with Accentia Technologies Ltd, the said company cannot be considered as good comparable. ...

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HC confirms ITAT’s deletion of notional interest adjustment on delayed AE receivables

Pr. CIT -V Vs Kusum Health Care Pvt. Ltd. (Delhi High Court) - Transfer Pricing : Impact of delayed associated enterprise receivables subsumed in working capital adjustment made by the assessee company. Delhi High Court confirms ITAT’s deletion of notional interest adjustment on delayed AE-receivables....

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TP adjustment in absence of interest cost for delay in realisation of dues not sustainable

Evonik Degussa India (P.) Ltd. Vs. Deputy Commissioner of Income Tax (OSD) (ITAT Mumbai) - 1. Research and development services provider could not be compared to a company and Transfer pricing Adjustment are not sustainable. 2. A concern mainly engaged in sale of chemical compounds could not be considered as a right comparable with that of assessee rendering support services in connectio...

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CBDT notifies rules for Country-By-Country Report and Master File rules

Notification No. 92/2017 / S.O. 3497(E) - (31/10/2017) - Information and documents to be kept and maintained under proviso to sub-section (I) of section 92D and to be furnished in terms of sub-section (4) of section 92D. 10DA. (1) Every person, being a constituent entity of an international group shall,-...

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Country-by-Country reporting & furnishing of master file- Draft TP rules

F. No. 370142/25/2017-TPL - (06/10/2017) - It is proposed to insert rulac 10DA, 10DB and form nos. 3CEBA to 3CEBE in the Income-tax Rules, 1962 (`the Rules'), laying down the guidelines for maintaining and furnishing of transfer pricing documentation in the Master File and Country-by-Country report. In this regard, the following guidelines a...

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CBDT Amends Form No. 3CEFA related to Application for Opting for Safe Harbour

Notification No. 62/2017-Income Tax - (18/07/2017) - These rules may be called the Income-tax (21st Amendment) Rules, 2017.They shall come into force and shall be deemed to have come into force from the 1st day of April, 2017. In the Income-tax Rules, 1962, in Appendix II, in Form No. 3CEFA, in paragraph 2, under the heading Eligible International Tra...

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Draft Notification on foreign company resident in India U/s. 115JH

F No 370142/19/2017-TPL - (15/06/2017) - CBDT invites comments and suggestions on the Draft Notification in respect of foreign company said to be resident in India under Section 115JH of the Income-tax Act, 1961...

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Transfer Pricing- CBDT notifies tolerance limit for A.Y. 2018-19

Notification No. 50/2017-Income Tax - (09/06/2017) - Central Government hereby notifies that where the variation between the arm's length price determined under section 92C of the Act and the price at which the international transaction or specified domestic transaction has actually been undertaken does not exceed one per cent of the latter in respect...

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Recent Posts in "Transfer Pricing"

Guidance Note on Transfer Pricing Report U/s. 92E of Income Tax Act, 1961

ICAI has released the 6th Edition (November 2017) of the Guidance Note on Report Under Section 92E of the Income Tax Act, 1961 (Transfer Pricing). This Guidance Note was previously revised in February, 2013 , August 2013 and October 2016. The ICAI has revised Guidance note on Report under Section 92E of the Income Tax […]...

Read More
Posted Under: Income Tax |

Transfer Pricing & GST

The Goods and Services Tax (GST) is being introduced in the country after 13 year long journey since it was first discussed in report by Kelkar Task Force on indirect taxes. Agreeably, one could count GST as country’s biggest tax reform which can trigger transformation on how businesses works across all industries and overhaul India’s...

Read More
Posted Under: Income Tax |

Accounts Receivable Overdue Not Subject to Transfer Pricing

It can be fairly concluded from the above judicial pronouncements that the receivable mentioned in the Explanation to Sec.92B can be taken up for transfer pricing scrutiny only when it is a standalone activity or a demonstrated approach is adopted by the assessee to use Accounts Receivable to have free working capital funding....

Read More
Posted Under: Income Tax |

Fighting Tax Crime: The Ten Global Principles

This report sets out the 10 essential principles for effectively fighting tax crimes. It covers the legal, institutional, administrative, and operational aspects necessary for putting in place an efficient system for fighting tax crimes and other financial crimes. It draws on the insights and experience of jurisdictions around the world. ...

Read More
Posted Under: Income Tax |

Effective Inter-Agency Co-Operation in Fighting Tax Crimes and Other Financial Crimes (Third Edition)

This report describes the current position in 51 countries as to the law and practice for domestic inter-agency co-operation in fighting tax crimes and other financial crimes including, for the first time, co-operation with authorities responsible for the investigation and prosecution of corruption. It identifies successful practices base...

Read More
Posted Under: Income Tax |

Tax Inspectors Without Borders – Bolstering domestic revenue collection through improved tax audit capacities

International tax experts gathered today at the OECD in Paris to share experiences and identify best practices in the implementation of Tax Inspectors Without Borders (TIWB) programmes....

Read More
Posted Under: Income Tax |

OECD updates transfer pricing country profiles reflecting transfer pricing legislation and practices

The OECD has published updated versions of transfer pricing country profiles (TPCP), reflecting the current transfer pricing legislation and practices of 31 participating countries. The country profiles contain up-to-date and harmonised information on key aspects of transfer pricing legislation, provided by countries themselves....

Read More
Posted Under: Income Tax |

Country-by-Country Reporting & Furnishing of Master File (Transfer Pricing)- Latest Developments

The Central Board of Direct Taxes (CBDT), on 31st October, 2017, has notified the final set of Rules for Maintaining and Furnishing of Transfer Pricing Documentation under Income Tax Rules 1962. Objective: To introduce provisions for additional TP documentation and Country – by – Country reporting to implement the recommendatio...

Read More
Posted Under: Income Tax |

Indirect transfers – Deciphering global perspective v. India’s outlook

After the recent worldwide implementation of OECD’s recommendations to prevent Base Erosion and Profit Shifting (BEPS), another forum (The Platform for Collaboration on Tax) has released a discussion draft on The Taxation of Offshore Indirect Transfers – A toolkit (hereafter, referred as the toolkit) for public comments on 1 August, 2...

Read More
Posted Under: Income Tax |

Salient features of Country-By-Country Report & Master File rules

The salient features of the Country-By-Country Report and Master File rules are as under: The threshold for the Country-By-Country Report is total consolidated group revenue of Rs. 5,500 crore or more....

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Posted Under: Income Tax |
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