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Transfer Pricing alerts

Insight with information

Deloitte's continuous alerts keep you updated with the latest that's happening. Watch this space regularly.

2013  
TP/13/2013 Special Bench is constituted by Delhi Tribunal on applicability of the turnover filter
   
TP/12/2013 Central Government notifies amended tolerance band for transfer pricing
   
TP/11/2013 CBDT issues two important circulars on Transfer Pricing applicable to Research and Development activities
   
TP/10/2013 Extra-ordinary expenses should be excluded while computing margins of the tested party; consolidated financial statements not preferred to compute margins of comparable companies; extreme profits / losses cannot be a sole criteria for rejection of comparables; concept of economies of scale does not apply to service industries
   
TP/09/2013 Interest rate on lending in foreign currency to foreign subsidiaries, domestic prime lending rate would have no applicability and the international rate fixed being LIBOR should be considered as the benchmark rate.
   
TP/08/2013 Indenting /commission transactions cannot be compared to purchase-and-sale trading transactions and internal comparable is preferable over external comparable
   
TP/07/2013 Advertising, Marketing and Promotion expenses upheld to be an international transaction, warranting the tax payer to be compensated on arm’s length principle by applying the Bright Line Test
   
TP/06/2013 Transactions between two domestic related parties cannot be covered under the extended definition of “International Transaction”
   
TP/05/2013 Irrespective of the fact whether the assessee is a contract manufacturer or full-fledged manufacturer, royalty paid for utilizing technical knowhow, should be considered as wholly and exclusively for the purpose of business and be allowed.
   
TP/04/2013 Sharing of net revenues in equal proportion is justified in case of similarities between the functional and risk profiles of the Assessee and the associated enterprises.
   
TP/03/2013 Shares in a company transferred by an enterprise alongwith a third party to an Associated enterprise under a single agreement would be considered as controlled transactions; Further, discounted cash flow method is an appropriate method for determining the arm’s length price of such a transaction.
   
TP/02/2013 Taxpayer’s business model cannot be rejected merely on assumptions, presumptions, inadequate analysis and without concrete evidence that the taxpayer is shifting profits to it Associated Enterprise.
   
TP/01/2013 Export incentive cannot, but the rebate received can be reduced from cost of goods sold for computing gross profit margin for determining the arm’s length price.

 

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