Increased number of intercompany transactions has made transfer pricing a leading risk management issue for global businesses.
The litigation, with regard to transfer pricing in India, is humongous. We aim to facilitate companies by providing practical transfer pricing Services & Solutions that are aligned to their global business and objectives and also provide controversy management.
The Advance Pricing Agreement is an agreement signed between the Central Board of Direct Taxes (CBDT) with the Taxpayer, determining the arm’s length price or specifying the manner in which the arm’s length price is to be determined, in relation to an international transaction. The agreement shall be valid for a period of 5 consecutive previous years. Such agreement shall be binding on the taxpayer and on the Principal Commissioner/Commissioner, and the income-tax authorities subordinate to him, in respect of the said person and the said transaction. There are three types of APAs i.e. Unilateral, Bilateral and Multilateral.
The Country-by-Country Reporting (CbCR) consists of a wide range of international measures framed to combat tax avoidance. The reports are required to include revenues, profits, taxes paid and certain measures of economic activity. This report has to be submitted by parent entity of an international group to the prescribed authority in its country of residence. Under Section 286 of the ITA, CbCR is mandatory for certain MNEs categories.
