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...

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...

Transfer pricing rules in India, were introduced in 2001, however, there are issues of tedious documentation, complicated procedures, rigorous penalties. Therefore, this subject has emerged as biggest source of courtroom battles. Recently, system has been improved by incorporating APAs, SHRs,...

World trade of goods and services is based upon the global supply chain and logistics management, and its flow is determined by the drivers of supply chain management. For a company to be successful in the new millennium where a paradigm shift has taken place it becomes necessary that its supply...

Introduced in 2001, transfer pricing (TP) rules in India have undergone a sea change and now with the inclusion of advance pricing agreements (APAs), safe harbour rules (SHRs) and more recent rules such as APA rollback, etc. the new TP regime is aimed to reduce litigations, provide more...

Overseas investors’ confidence is an important factor that attracts FDI. The tax and regulatory policy in the respective countries can either be a major attraction or repulsion, as far as investor sentiment is concerned. In India, this issue has had many references in the literature. To bypass...