sitemapHome | Registration | Job Portal for CA's | Expert Exchange | Currency Converter | Post Matrimonial Ads | Post Property Ads
News shortcuts: From the Courts | News Headlines | VAT (Value Added Tax) | Placements & Empanelment | Various Acts & Rules | Latest Circulars | New Forms | Forex | Auditing | Direct Tax | Customs and Excise | ICAI | Corporate Law | Markets | Students | General | Mergers and Acquisitions | Continuing Prof. Edu. | Budget Extravaganza | Transfer Pricing | GST - Goods and Services Tax
Latest Expert Exchange
From the Courts »
  Suresh M. Jamkhindikar vs. ACIT (Bombay High Court)
 Mangammal @ Thulasi vs. T.B. Raju (Supreme Court)
 Mahabir Industries vs. PCIT (Supreme Court)
  Oriental Bank Of Commerce Vs. Additional Commissioner Of Income Tax
  Suresh M. Jamkhindikar vs. ACIT (Bombay High Court)
  Union of India vs. Pirthwi Singh (Supreme Court)
 Cromption Greaves Limited vs. CIT (ITAT Mumbai)
 Director Of Income Tax Vs. M/s. Modiluft Ltd.
 Director Of Income Tax Vs. M/s. Royal Airways Ltd.
 Lally Motors India (P.) Ltd vs. PCIT (ITAT Amritsar)
  Mehsana District Co-operative vs. DCIT (Gujarat High Court)

Transfer pricing row with two arms of a British company settled
February, 02nd 2016

The tax authorities have solved transfer pricing disputes with two Indian subsidiaries of a UK company involved in manufacturing of automotive and industrial component.

The disputes were solved through bilateral advance pricing agreements (APAs), signed with these companies and the British government.

The APAs cover 2013-14 to 2017-18 and also have a "rollback" provision for two years (2011-12 and 2012-13). Transfer pricing disputes on similar transactions were recently resolved under a mutual agreement procedure (MAP) for each of these companies for 2006-07 to 2010-11.

With the signing of the bilateral APAs, the two Indian companies have been provided with tax certainty for 12 years each (five years under MAP and seven years under APA).

The two APAs are significant because these address the issues of payment of management & service charges and payment of royalty. These transactions generally face prolonged and multilayered transfer pricing disputes.

With this signing, the Central Board of Direct Taxes (CBDT) has so far signed 41 APAs - 38 unilateral and three bilateral. A bilateral APA was signed with Japan in December 2014. In unilateral APAs, only the companies concerned and Indian tax authorities are involved. However, in bilateral APAs, the government of the country the multinational concerned is headquartered is also involved.

The government has expedited resolving transfer pricing disputes. It has solved over 100 transfer pricing disputes over the previous year with US companies engaged in sectors such as information technology (software development) services [ITS] and information technology enabled services [ITeS] segments. This is expected to pave the way for greater transfer pricing cooperation and enhance foreign investment flow.

Home | About Us | Terms and Conditions | Contact Us
Copyright 2018 CAinINDIA All Right Reserved.
Designed and Developed by Binarysoft Technologies Pvt. Ltd.
Outsourcing Test Solutions Software Testing Software Bug Testing Software Issues Tracking Software Issue Fix Software Code Optimization Database Design Optimization

Transfer Pricing | International Taxation | Business Consulting | Corporate Compliance and Consulting | Assurance and Risk Advisory | Indirect Taxes | Direct Taxes | Transaction Advisory | Regular Compliance and Reporting | Tax Assessments | International Taxation Advisory | Capital Structuring | Withholding tax advisory | Expatriate Tax Reporting | Litigation | Badges | Club Badges | Seals | Military Insignias | Emblems | Family Crest | Software Development India | Software Development Company | SEO Company | Web Application Development | MLM Software | MLM Solutions