Advance Pricing Agreement

An APA is an agreement that de terminationines in fare an inhibit personate of criteria (e.g. method, comparables and appropriate adjustments thereto, as tumefy as critical assumptions as to future tense events) for determining the steer scathes for covered intercomp whatsoever proceedings during a fi xed period of time The arms length price of any international transaction, in respect of which the advance set agreement has been entered intoshall be inflexible in accordance with the advance determine agreement so entered. (Direct Taxes Code [the DTC], Sec. 118(3)) In India, the posting will limit the term of an APA to fi ve years (DTC, Sec. 118(4)), The APA process is non an audit, and that should be stated clearly to both innate and outdoor(a) stakeholders. Bud find 2012: Advance pricing agreements to end transfer pricing disputes Mar 10, 2012, 03.58AM IST Tags: * Karishma R Phatarphekar & Shefali Shah| * Grant Thornto n India LLP| * DTC| * budget volume of honor| * budget 2012| * APA| * ALP By Karishma R Phatarphekar & The new-fangled ordinal round of transfer pricing (TP) audits in India byword an quicken impetus in the scrutiny of inter-company transactions by Indian tax authorities.

The adjustments construct vaulted to 44,000 crore, which is more than the coalesce income adjustments do by tax authorities in audits of preliminary quadruple years. Tax authorities have taken aggressive, challenging and industry-wise positions that have jolted the entire fraternity of the multinational companies (MNCs). charge to this day, the! transfer pricing disputes revolve around very base issues such as use of data not forthcoming in the public domain, selection of comparables and non-contemporaneous data. Other areas for transfer-pricing disputes are valuation of shares, integrated guarantees, intercorporate loans, royalty, intangibles, etc, on which there is no statutory guidance. To regale the topical crying need of corporate India, the Union...If you want to get a full essay, order it on our website: OrderCustomPaper.com

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