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: form 3cd :: ACCOUNTING STANDARDS :: due date for vat payment :: TAX RATES - GOODS TAXABLE @ 4% :: cpt :: ACCOUNTING STANDARD :: empanelment :: TDS :: articles on VAT and GST in India :: ARTICLES ON INPUT TAX CREDIT IN VAT :: VAT RATES :: list of goods taxed at 4% :: VAT Audit :: Central Excise rule to resale the machines to a new company :: ICAI offer Get Windows 7,Office 2010 in Rs.799 Taxes
« Budget Extravaganza »
 Budget 2017: Last stretch or a turning point?
 Is Budget 2017 the most difficult one till date?
 Is Budget 2017 the most difficult one till date?
 Budget 2017: Why Centre must clarify, its intentions on income tax Act
 Budget may put consumers before taxes to spur demand
 Budget 2017: Income tax payer friendly budget expected; Arun Jaitley may provide sops to boost housing sector
 Are you expecting good tax breaks in Budget 2017? Think again
 Budget 2017: Home insurance premium should get income tax exemption
 Demonetisation may be the trigger for any increase in service tax rate this budget
 10 things Arun Jaitley can do to make it a Budget for the middle class
 How budget 2017 can ease pain of demonetisation via income tax sops

Advance pricing to boost offshoring
July, 06th 2009

India should rationalise its transfer pricing norms and introduce the concept of advance pricing arrangement (APA) to retain its position as an attractive offshoring destination, a leading tax expert has said.

Most multinationals want simple and rational transfer pricing norms as offshoring is essentially a thin margin business. The comparables that are used sometimes tend to ignore this reality, Steven E Fortier, global managing principal, global transfer pricing services, KPMG, told ET.

APA is an agreement between a taxpayer and tax authorities that allows both to set out in advance the method of determining the transfer pricing for inter-company transactions. Most countries allow for APAs under their transfer pricing regulations as they help prevent actual or potential pricing disputes in a co-operative manner.

They also provide an alternative to traditional dispute resolution. Industry and tax experts in India have demanded APAs be put in place ever since transfer pricing laws were introduced in the country in 2001. CII has pitched for APAs in its pre-Budget memorandum to Finance Minister Pranab Mukherjee.

Taxpayers should be allowed to use a method (other than prescribed by the Central Board of Direct Taxes) that is most relevant to determine arms length price in an international transaction, provided the assessee can demonstrate that such a method is more relevant to business operations or specific transactions, CII said.

Transfer pricing provisions in general require income arising from an international transaction between two or more related organisations to be calculated at an arms length price. The basic test of this is that they should be comparable to similar transactions between unrelated parties.

He pointed out that APAs provide much-needed certainty that foreign companies look for while making an investment decision. Also, APAs prevent unnecessary and protracted litigation that are going on over transfer pricing in India, he pointed.

While a sub-group set up under the international taxation division of CBDT, the apex body administering direct taxes, had made a recommendation in this regard in 2007, there has been little progress. Bilateral agreements with countries to make APAs more effective for multinational corporate taxpayers should also be looked at, he said.

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

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