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Transfer Pricing

Transfer Pricing Consultant

Transfer pricing are the prices created once a corporation provides products, services or finance to a different company to that it's connected. It is an internationally accepted principle that transactions between connected parties (associated enterprises) ought to be primarily based upon an equivalent terms as between unrelated parties i.e. ought to be at Arm’s Length. Each the Double Tax Avoidance treaties entered into between countries and domestic tax legislation of assorted countries has adopted the length principle.

According to Indian Tax laws, a corporation is termed as an associated enterprise with regard to the opposite enterprise, beneath the subsequent conditions:

  • The actual company is concerned directly or indirectly within the management, control, or the capital of the opposite company.
  • If any person/persons of the company who is/are concerned directly or indirectly within the management, control, or the capital of 1 company is/are concerned directly or indirectly within the management, control, or the capital of the opposite company.
  • Apart from the on top of there are several deeming provisions noncommissioned beneath Section 92A of the Income-tax Act, 1961.

The Finance Bill 2012 has solid Transfer rating web wider and deeper by well increasing the scope of transfer pricing (TP) provisions by domestic transactions for the primary time. The subsequent transactions (“specified domestic transactions”) are enclosed if their mixture exceeds INR fifty million in a year

  • Any expenditure to that section 40A (2) (b) applies
  • Any transaction referred in section 80A
  • Any transaction with someone laid out in 80-IA (10)
  • Any transaction referred in Chapter VI-A, Section 10AA to that 80(10) or 80(18) applies
  • The other transaction which can be prescribed