India is among many countries which have embraced Transfer Pricing (“TP”) regulations with prescribed mandatory documentation. TP is a complex tax. With, Base Erosion and Profit Shifting (“BEPS”) TP has become a focus area. Implementation of General Anti Avoidance Regulations (GAAR) and Place of Effective Management (POEM), have made it more complicated. If the TP approach is not correct , clients may face following issues
Transfer Pricing has been made applicable on certain domestic transactions defined as “Specified Domestic Transactions” (“SDT”) with effect from Financial Year 2012-13. These regulations become applicable where the aggregate amount of all such domestic transactions exceeds INR 20 Crore in a financial year.
We have tailored our International services in such a manner which takes care of the tax and regulatory framework that is ever-changing globally thereby adding complexities to otherwise already complex and uncertain tax environment. The major recent developments, below, require businesses to be extremely knowledgeable before planning International setup.