International transfer pricing controversies and subsequent litigations with taxation authorities have become the major issues in foreign investments and international technology transfers. Disputes between the taxation authorities and MNCs are mounting up as most of the MNCs are now contesting...

The transfer pricing regulations in India came into force in 2001 with their effective audits beginning from the 2003 onwards. The Central Board of Direct Taxation has constituted a special cell for all transfer pricing audits. Over the past four years or so, there has been a significant...

One of the important issues in the areas of international taxation, international technology transfer and foreign investment by the MNCs that has been drawing greater attention of tax authorities worldwide is the issue of transfer pricing i.e. the compensation paid for intra-group services to...

The Government of India for the first time in 2001 introduced the transfer price regulations in the country with the transfer pricing audits effectively beginning from 2003 onwards. The onerous documentation requirements and stringent penalties prescribed by the regulations were a cause of...

Firms operating with foreign collaborations (FCA units) have been facing a high degree of dependence on the parent MNEs (Multi-national Enterprises) compared to their local counterparts (Non-FAC units) owing to reasons like larger imports of raw materials, machinery, equipments and spares by...

In consonance with globalization, the International Transfer Pricing (ITP) rules have also been introduced in the countries, where they did not exist, or reformed as per the OECD guidelines in a number of countries where they already existed. In many countries the process of revamping these...

Ever since the transfer pricing rules introduced in India and China they have undergone various updates based upon the requirements and need of countries and trade organisations. Concepts of the APA and SHRs have also been incorporated in their transfer pricing legislations and both countries...

Transfer pricing remains an inevitable tool for MNCs to carry out intra-company transactions. From the literature, misuse of transfer pricing has been observed with respect to advertisement, marketing and promotion (AMP). This research paper attempts to demonstrate the instances wherein abuse of...

The Transfer pricing rules in India which were first introduce, in the year 2001 have been regularly modified and updated and presently with the inclusion of APA and SHR system we are having the new transfer pricing regime the rules of which are at the par with most of the advance counties the...