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: ARTICLES ON INPUT TAX CREDIT IN VAT :: ACCOUNTING STANDARDS :: list of goods taxed at 4% :: empanelment :: cpt :: due date for vat payment :: Central Excise rule to resale the machines to a new company :: form 3cd :: ICAI offer Get Windows 7,Office 2010 in Rs.799 Taxes :: VAT RATES :: VAT Audit :: TAX RATES - GOODS TAXABLE @ 4% :: TDS :: ACCOUNTING STANDARD :: articles on VAT and GST in India
 
 
News Headlines »
 How to link your Aadhaar and PAN details to file income-tax returns
 How to calculate capital gains tax on property sold at less than stamp value?
 Return Filing - Under GST, this is how you will file tax returns from July 1
 Income tax filing FAQs part 1
 Filing Income Tax Returns? Things To Keep In Mind As Deadline Approaches
 Filing of online return for 4th quarter of 2016-17- extension of period thereof.
 New tax accounting standards may reduce leeway for infrastructure companies
 GST – CONCEPT & STATUS – As on 01st May, 2017
 Govt extends VAT deadline, relief for developers
 Income Tax Appellate Tribunal Rules, 2017
 Got your Form 16? You should file income tax returns early to enjoy benefits

Finmin to set up appellate body for monitoring international taxation
June, 08th 2007

Keen to avoid a repetition of the fracas like that between Morgan Stanley and the income tax department, the finance ministry is planning to set up an appellate body for international taxation.
 
The authority will deal exclusively with rulings on transfer pricing, to ensure that arm's length price has been maintained in all transactions. This means multi national companies will get a more transparent and clear rulings on their business practices.

The body would be modelled along the lines of the already functioning authority of advanced rulings, that decides on all income tax issues. At present, advance rulings in the country are available only for income tax and customs.

However while the terms of reference and the consequent legislation are still to be finalised, it is likely that the authority would give decisions for only prospective transactions by non-residents and not stir a hornets nest by bringing existing transactions within its purview.

Commenting on the move, Vispi P Patel, executive director, transfer pricing Price Waterhouse Coopers said, This is surely a step in the right direction, but the authoritys terms of reference should ideally be wide enough to include both existing and prospective transactions.

New Era
The authority will deal exclusively with rulings on transfer pricing
The body will be modelled on the lines of the authority of advanced rulings
It may also augur advance pricing agreements
 
Also, while the authority would help lessen litigation and bring more certainty to transfer pricing regulations in the country, it is yet to be decided whether it would also act as the final arbitrator on all issues relating to transfer pricing.

In the Morgan Stanley case, the AAR had ruled that a portion of Morgan Stanleys global profits are not liable to be taxed in India as long as it paid an arms length price to the Indian subsidiary. The questions had arisen whether outsourcing to captive service providers would result in a permanent establishment (PE) coming into existence. The case has now been referred to the Supreme Court.

The authority may also be the harbinger for advance pricing agreements for companies in the form of Advance Pricing Agreements (APAs) with the authority, Patel added. They can either be unilateral or multilateral.

Transfer pricing refers to the value attached to transfers of goods, services and technology between related entities as well as to the value attached to transfers between unrelated parties, which are controlled by a common entity.

 
 
Home | About Us | Terms and Conditions | Contact Us
Copyright 2017 CAinINDIA All Right Reserved.
Designed and Developed by Binarysoft Technologies Pvt. Ltd.
Customer relationship management software CRM software Operational CRM Collaborative CRM

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