#Transfer Pricing
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1,377 articlesIncome Tax

Income Tax
Mere use of foreign word is immaterial to fall within ambit of international transaction
Income Tax

Income Tax
Mere usage of name of Foreign AE not convert a transaction into international transaction
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Income Tax
Arm’s length interest rate computable based on market determined rate applicable to currency in which loan is repayable
Income Tax

Income Tax
TNM Method not appropriate in determining ALP in capital goods purchase transaction
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Income Tax
Analogy between UN, OECD Model Tax Convention and Indian Tax Treaties
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Income Tax
UAE Transfer Pricing Regulations
Finance

Finance
Global Minimum Tax (GMT) on track for a 1st Jan 2024 launch: Agreed Administrative Guide released in Feb 2023
Income Tax

Income Tax
Ad-hoc determination of ALP by TPO de-hors Section 92C(1) & cannot be sustained
Income Tax

Income Tax
Penalty u/s. 271(1)(c) unsustainable as no adjustment on transfer pricing issue wouldn’t subsist
Income Tax

Income Tax
Budget 2023 reduces time provided for furnishing TP report
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Income Tax
Transfer Pricing: For outbound loans LIBOR rate should be adopted but not PLR of Indian Banks
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Income Tax
Reasons to Form an Offshore Company This Year
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Income Tax
High turnover is a ground to exclude a company from list of comparable companies
Income Tax

Income Tax
