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Transfer Pricing »
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 I T department keeps tolerance range for transfer pricing unchanged
 India retains transfer pricing tolerance range for 2019 20
 PCIT rightly directed the Bank of India s case to Transfer Pricing Officer for determining ALP ITAT
 Key Highlights Of The 2nd Edition Of KSA Transfer Pricing Guidelines
 ITAT deletes Penalty since Assessee applied Transfer Pricing Provisions with Good faith and Due Diligence
 Change in transfer pricing regulations to help MNCs
 National High Speed Rail Corporation Limited, New Delhi, Delhi
 Deals of the day-Mergers and acquisitions September 3, 2019
 Transfer pricing documentation due by year-end
 Transfer pricing amendments – a step towards certainty
 key international tax and transfer pricing developments

OECD issues discussion drafts on permanent establishment status and transfer pricing action plans
November, 06th 2014

The OECD has released two discussion drafts. The first responds to Action 7 of the BEPS Action Plan, which addresses issues related to the artificial avoidance of permanent establishment (PE) status. Action 7 calls for the development of changes to the definition of PE to prevent the artificial avoidance of PE status in relation to BEPS, including through the use of commissionaire arrangements and specific activity exemptions.

The second OECD discussion draft responds to Action 10 of the BEPS Action Plan. Action 10 calls for transfer pricing rules to provide protection against common types of base eroding payments, such as management fees and head office expenses. This discussion draft proposes to do this by identifying a wide category of common intra-group services commanding a very limited profit mark-up on costs, applying a consistent allocation key for all recipients, and providing greater transparency through specific reporting requirements

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