International Taxation And Transfer Pricing
As MNCs look for better ways to participate in the global market, cross-border transactions between associated enterprises are increasing in volume and complications. There has been a remarkable rise in litigation worldwide as more and more Governments attempt to enforce their transfer pricing rules vigorously.

Transfer Pricing

In India, there are considerable Transfer pricing regulations in place according to which an arm's length standard is the criteria for judgment.

Transfer pricing is simply the act of pricing of goods and services or intangibles when the same is given for use or consumption to a related party. It can be either Market-based, i.e. equivalent to what is being charged in the outside market for similar goods, or it can be non-market based. Importantly, two-thirds of the managers say their transfer pricing is non-market based.

The Indian landscape is also witnessing change, with safe harbor rules and advance pricing arrangements on the cards and MAP evolving as an alternate dispute resolution mechanism. The Transfer pricing Regulations were introduced in India vide the Finance Act, 2001 by substitution of the existing 92 and introduction of new sections 92A to 92F in the Income Tax Act and relevant rules 10A to 10E in the Income Tax Rules, 1962.

Suresh Anchaliya & Co. shall help you with the following services:

  • Advise on drafting of transfer pricing arrangements between group entities.
  • Analysis of the transactions between group entities from arm's length point of view.
  • Transfer Pricing Documentations.
  • Transfer pricing audit and submission of Form 3CEB to Transfer pricing officer.

Double Tax Avoidance Advisory

The Central Government of India has entered into agreements with various Governments of countries outside India for avoidance of double tax effect levied on an assessee's income in both countries. The Double Tax Avoidance Agreement (DTAA) encourages and emphasizes the need for transparent cross border transactions. Ergo, DTAA has become very important to prevent and reduce undue hardship that can be faced by assessees by having to pay taxes in more than one jurisdiction of the world.

Our endeavor is to advise our clients through all the stages of the cross border transactions to mitigate the hardship of double taxation by advising on the incidence of tax based on the nature of the income and expenditure incurred keeping as per the provisions of the Indian Tax laws and the provisions of the double tax avoidance agreements, withholding tax issues and the related compliances.

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