Transfer Pricing alerts - 2010Insight with information |
Deloitte's continuous alerts keep you updated with the latest that's happening. Watch this space regularly.
| 2010 | |
| TP/07/2010 | On 22 July the Organisation for Economic Co-operation and Development (OECD) released major revisions of its transfer pricing guidelines. this alert provides brief details of these recent developments |
| TP/06/2010 | Recently, Delhi High court has, in the case of Maruti Suzuki India Ltd, made observations on proper opportunity to be provided by tax authorities before taking any adverse decision and on the determination of the arm’s length price of intangible in the form of trademark. |
| TP/05/2010 | Mumbai ITAT ruling upholds per hour billing rate published by NASSCOM for a specific business segment as an external CUP in determining the arm’s length price. |
| TP/04/2010 | In a recent ruling, the Delhi ITAT has held that the interest free loan granted by an Indian entity to its associated enterprise is required to comply with arm’s length principle and cannot be characterized as quasi-equity. |
| TP/02/2010 | This judgement emphasizes that stage in the life cycle of an enterprise should be taken into consideration for the selection of comparables. Ruling implicitly accepts the concept of Inter-Quartile Range by upholding of rejection of outliers. The judgement also establishes that the assessee cannot be prevented from objecting its own comparable company as long as it ensures fair justice to arrive at arm’s length price. |
| TP/01/2010 | This judgement emphasizes the fact that total amount of transfer pricing adjustment cannot exceed the absolute amount of revenue realized by the associated enterprise from third parties and idle capacity adjustment should be allowed to the taxpayer to improve the comparability analysis. |
