The year 2015 was arguably a momentous one for transfer pricing (TP). A combination of local and international developments will mark it as a period which defined the future direction of this subject. Key Developments The Organization for Economic Cooperation & Development (OECD) released final reports as part of its… – Continue reading
Transfer pricing adjustment cannot be made in a case where the tax rate in the country of the Associated Enterprise is higher than the Indian rate and where, accordingly, establishment of tax avoidance or manipulation of prices or establishment of shifting of profits is not possible. Only after proper application… – Continue reading
On a warm afternoon last month, Mexican central bank Governor Agustin Carstens looked out over sun-drenched piles of dirt and construction equipment near Guadalajara and hailed the groundbreaking of a new currency-printing plant as a sign of a solid economy. There’s one catalyst for rising cash demand that isn’t a… – Continue reading
The Transactional Net Margin Method (‘TNMM’) is a prescribed method for determining the arm’s length price in some cases. It also enjoins the adjustment owing to capacity under-utilization differences. Sizes of entities and level of activities differ, so does the available comparables for the purpose of transfer pricing adjustments. The… – Continue reading
