Arms Length Pricing

Applicability of RBI Guidelines to Income Tax

Introduction We are aware that foreign exchange regulations are governed by Reserve Bank of India (˜RBI™) and income tax regulations by the Central Government. Yet, is it possible to conclude that limits laid down by RBI can be considered as  Arm™s Length Price (˜ALP™) for the purposes of transfer pricing under the under Income tax… Read More

Tags: ALPArms Length Pricingforeign direct investmentIncome taxIndiamoney launderingReserve Bank of IndiaRoyalties

Business advances also need to be benchmarked on Libor ALP

CLR Editorial Note: The assessee, an Indian company, had given loans of Rs. 15.65 crores to its Associated Enterprises s in USA, Singapore and Bahrain. In its assessment report, it claimed that the said loans were working capital advances given for commercial consideration to secure the business and that no interest was recoverable on it.… Read More

Tags: Arms Length PricingIndiaLIBORtransfer pricing

Arms Length Pricing – RBI Approvals are deemed irrelevant

Ratio of the Case: A Press note issued in relation to an FDI policy thus allowing payment of royalty amounting to a certain percentage of sales under automatic route, cannot be viewed as being done at Arms Length. The FDI policy which permits payment of a percentage of royalty is meant only for remittance of the royalty… Read More

Tags: ALPArm's length principleArms Length PricingCommonwealth Law ReportsFDIforeign direct investmentI T ActIndiaMinistry of Commerce & Industryrbi

Corporate Law Referencer

Recent Articles

Recent Legal updates

Recent Gst Updates