Latest Expert Exchange Queries
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) | Service Tax | Sales Tax | Placements & Empanelment | Various Acts & Rules | Latest Circulars | New Forms | Forex | Auditing | Direct Tax | Customs and Excise | ICAI | Corporate Law | Markets | Students | General | Indirect Tax | Mergers and Acquisitions | Continuing Prof. Edu. | Budget Extravaganza | Transfer Pricing
 
 
 
 
Popular Search: ACCOUNTING STANDARD :: due date for vat payment :: ARTICLES ON INPUT TAX CREDIT IN VAT :: ACCOUNTING STANDARDS :: VAT Audit :: ICAI offer Get Windows 7,Office 2010 in Rs.799 Taxes :: Central Excise rule to resale the machines to a new company :: cpt :: TAX RATES - GOODS TAXABLE @ 4% :: VAT RATES :: list of goods taxed at 4% :: empanelment :: articles on VAT and GST in India :: form 3cd :: TDS
 
 
« Transfer Pricing »
 Secondary adjustments to become a reality under Indian transfer pricing regime
  Budget introduces secondary adjustments in transfer pricing
 Transfer pricing: Centre moves forward, introduces ‘secondary adjustments’
 Domestic transfer pricing leeway provides a loophole for Indian companies
 Budget introduces secondary adjustments in transfer pricing
 Transfer Pricing Rules – 2017 novelties
 OECD BEPS transfer pricing rules likely to cost multinationals, but not the IRS
 Transfer pricing’ offers lots of room for manipulating international payments
 New rules for transfer pricing
 Updated UN manual reveals India’s transfer pricing positions
 Budget 2017: What Clarity Can It Bring To International Taxation And Transfer Pricing?

Transfer pricing changes proposed to address financial benefit due to incorrect pricing
May, 27th 2016

The government is consulting on the introduction of a secondary adjustment rule into the UK’s transfer pricing legislation, probing questions around whether such a rule would address the financial benefit arising from incorrect pricing within transfer pricing arrangements, which remains after application of the current rules

HMRC says the introduction of the secondary adjustment rule would complement the government’s work to date, both domestically and internationally, in tackling taxpayers entering into aggressive transfer pricing arrangements to avoid tax in the UK.

The suggested changes follow on from governmental efforts to address tax planning and relates to the UK’s role in the OECD/G20 effort to tackle Base Erosion and Profit Shifting. It was also included among the early action points which were expected to target aggressive transfer pricing practices by multinationals.

The arm’s length principle has been adopted internationally for transfer pricing rules. It provides an agreed basis for the fair allocation of profit on cross border transactions between connected parties and also avoids double taxation.

However, this also means that changes to that principle need the same international agreement and can take some time to agree.

The UK’s transfer pricing rules calculate the taxable profits on the price that would have been charged at arm’s length. This is achieved via an adjustment (the primary adjustment) to the price that is effective for tax purposes.

As the primary adjustment is only effective for tax purposes, any cash benefit from non-arm’s length pricing can accumulate in an overseas company, often located in a low tax country.

But a secondary adjustment rule would counter this.

HMRC says the rules are already an internationally recognised approach, part of transfer pricing rules applied in several leading jurisdictions including the US, Canada, France and EU member states.

 
 
Home | About Us | Terms and Conditions | Contact Us
Copyright 2017 CAinINDIA All Right Reserved.
Designed and Developed by Binarysoft Technologies Pvt. Ltd.
Binarysoft Technologies - Achievements

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