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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.

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