Applicability of Transfer Pricing (“TP”) provisions was earlier limited to International Transactions only. With effect from April 1, 2013, the scope of Transfer Pricing provisions extended to “Specified Domestic Transactions (“SDT”).
With the applicability of transfer pricing provisions on Specified Domestic Transactions, it is the obligation on the taxpayer to report / document and substantiates the arm’s length nature of such transaction.
Transfer pricing regulations were extended to include transactions entered into with domestic parties or by an undertaking with other undertakings of the same entity for the … Read more
Transfer Pricing (“TP”) regulations have been at the forefront of corporate headlines over the last few years due to the increasing number of controversies resulting out of tax structuring by multinational companies in India. What makes the topic both contentious and interesting is that regulators view the various techniques applied to inter-corporate transactions as purportedly planned with the intent of achieving benefits of comparable labor cost and tax advantage at the cost of a countries tax revenues.
Hence, there was a need to introduce a uniform and internationally accepted mechanism of determining reasonable, fair and equitable profits and tax … Read more