Organisation for Economic Co-operation and Development

United Nations Practical Manual on Transfer Pricing

The United Nations has recently released a publication namely Practical Manual on Transfer Pricing. The Manual is said to contain valuable discussions on a large number of important topics related to the subject of Transfer pricing. There is a detailed discussion on the different types of transfer methods available for calculation of transfer price, such… Read More

Tags: Australian Labor PartyCommonwealth Law ReportsGovernmentIndiaMultilateralOrganisation for Economic Co-operation and Developmenttransfer pricingUnited Nations

Transfer Pricing Laws applicable to ITES/ BPO Sector explained by ITAT

CLR Editorial Notes:  The assessee, in this Transfer Pricing related case, had raised three contentious issues in support of the  contention that its charges were at Arms Length: (i) that the assessee was engaged in the low end activity of voice based call centre and that the comparables chosen by the Tranfer Pricing Officer in… Read More

Tags: ALPCommonwealth Law ReportsIndiaOECDOrganisation for Economic Co-operation and DevelopmentTPO

Online advertising on foreign entity not taxable in India – An Analysis

Introduction The recent decision of ITO v. Right Florists P. L.   I.T.A. No. : 1336/ Kol. / 2011, deals with India™s right to tax payment made by an Indian entity (˜ICO™) to a foreign entity for online advertising services provided by the latter. Here, ICO made payments to Google Ireland and Yahoo USA (together… Read More

Tags: FCOForeign and Commonwealth OfficeGovernmentHyundai Heavy IndustriesIncome Tax ActIncome Tax Act 1961IndiaItalyOnline advertisingOrganisation for Economic Co-operation and DevelopmentPermanent establishmentThe Income-tax Act 1961United States

ALP has to be the Arithmetic mean of all prices arrived through various methods

Ratio of the Case: If more than one price is determined by the most appropriate method, the ALP has to be the arithmetical mean of such prices CLR Editorial Notes: The assessee was engaged in providing software development support services by which it developed software upon the instructions of its parent associated enterprise (IKOS Systems Inc).… Read More

Tags: ALPArm's length principleITATOrganisation for Economic Co-operation and DevelopmentTPOTribunal

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