Tuesday, May 8, 2018

"TPR" - a muddled world of cnfusion, worse confounded; reasulting in a cesspool of 'stimulated litigation' - a revisit for ..

< satisfying own (personal) curiosity, out of sheer compassion for one and all concerned - in its inclusive sense !





“In order to reduce transfer pricing disputes, to provide certainty to taxpayers, to align safe harbour margins with industry standards and to enlarge the scope of safe harbour transactions, the CBDT has notified a new safe harbour regime based on the report of the Committee set up in this regard,” the CBDT said in a statement on Thursday.



< "Addressing your needs
Today multinationals are operating in an environment of unprecedented complexity.
With the escalating volume and varied nature of intercompany transactions and
transfer pricing regimes, it comes as no surprise that transfer pricing is perceived as
the most significant issue being faced by global businesses. Tax authorities worldwide
are attacking transfer pricing methodologies with increasing frequency. India, being
no exception to this phenomenon, has infact seen a surge of transfer pricing audits,
both in terms of the percentage of cases suffering transfer pricing adjustments as well
as the quantum of adjustments. As a critical issue, transfer pricing, therefore, requires
an effective solution.
With a view to reduce the number of transfer pricing audits and to address the
numerous cases in dispute, Advance Pricing Agreement (APA) provisions and safe
harbor rules have been introduced in India. While this move by the Finance Ministry is
very positive and is a significant step towards having a stable and non-adversarial tax
regime, taxpayers are likely to encounter some additional burden with the application
of transfer pricing provisions to certain specified domestic transactions (SDT) and
recent focus of the tax authorities on issues pertaining to trade and marketing
intangibles. Extension of transfer pricing provisions to SDT will require taxpayers to
evaluate their domestic intra-group dealings (including business structures) to assess
the impact of the arm’s length standard on their existing pricing policies, evaluate
the related implications and determine approaches to manage risks and ensure
compliance. In addition, with the introduction of the arm’s length concept for related
party transactions in the Companies Act, 2013, companies will have to assess and
evaluate the impact of these provisions on their compliance and reporting obligations
under the provisions of company law.
At Deloitte, we have a team of tax/transfer pricing professionals who can provide
tailored advice and assist you in navigating through the ‘transfer pricing storm’. "


WANTED to KNOW ? >

https://www.informationvine.com/index?qsrc=999&qo=semQuery&ad=semD&o=758652&l=sem&askid=17bd930b-a497-49e8-98ac-a042f5dd0d4e-0-iv_gsb&q=transfer%20pricing%20articles&dqi=&am=broad&an=google_s


Articles 

TAXMANN


A ) 11 Records 
Description: https://www.taxmann.com/images/righttick.png
1. [2018] 91 taxmann.com 39 (Article) - V. SWAMINATHAN
Opinion : Computation of Capital Gains for FY 2017-18

2. [2015] 56 taxmann.com 398 (Article) - V. SWAMINATHAN
MAT - Red Carpet for FIIs turns into taxation MAT - An insight ...

3. [2015] 53 taxmann.com 408 (Article) - V. SWAMINATHAN
Finance (No. 2) Act 2014 – Retro-Changes a Critique

4. [2009] 181 Taxman 10 (MAG) - V. SWAMINATHAN
INTERNATIONAL TAXATION - SECTION 79 OF INCOME-TAX ACT V. ...

5. [2009] 176 Taxman 129 (MAG) - V. SWAMINATHAN
INTERNATIONAL TAXATION - OECD MODEL TAX CONVENTION - 2008 UPDATE

6. [2009] 176 Taxman 82 (MAG) - V. SWAMINATHAN
INTERNATIONAL TAXATION - HIGH COURT’S DECISION IN THE MATTER OF ...

7. [2008] 172 Taxman 49 (ART) - V. SWAMINATHAN
TRANSFER PRICING - TAXTREATIES V. TRANSFER PRICING

8. [2007] 165 Taxman 165 (ART) - V. SWAMINATHAN
TRANSFER PRICING - ITAT ON TRANSFER PRICING REGULATIONS

9. [2007] 158 Taxman 90 (ART) - V. SWAMINATHAN
PERSONAL TAXATION - COMPANY LEASE ACCOMMODATION AND RENT ...

10. [2006] 160 Taxman 145 (ART) - V. SWAMINATHAN
BUSINESS EXPENDITURE - APEX COURT ON ILLEGAL BUSINESS - A STUDY

11. [2006] 156 Taxman 121 (ART) - V. SWAMINATHAN?
CASE STUDY/BUSINESS EXPENDITURE - ILLEGAL BUSINESS - CAN IT BE ...


B) : 4 Records 
Description: https://www.taxmann.com/images/righttick.png

   (2007) 10 CAT    535

   (2008) 301 ITR    13

  (2007) 10  CAT   445

  (2007) 295 ITR     17

TAGS (Blogs) to search - 'Transfer Pricing' ; 'Indirect Transfer' >>>>





No comments:

Post a Comment