Transfer Pricing

Draft Place of Effective Management (PoEM) Rules

February 15, 2016

Residential status of the companies is an important factor in deciding their tax liabilities. The income tax act provides that a company is resident in India if it fulfils either of the following two conditions: It is an Indian company During a particular financial year, the control...

Base Erosion and Profit Sharing (BEPS)

November 23, 2015

Base Erosion and Profit Sharing (BEPS) has emerged as one of the most important challenges for the governments across the world today. The globalization, privatization and liberalization has resulted into free movement of capital and labour, shift of manufacturing base from high cost to low cost locations,...

India’s Transfer Pricing Problem

November 23, 2015

Transfer Price is the price of the goods and services sold between related entities such as – parent company and daughter (subsidiary) company; or between branches of same entity. The fixing of price of goods and services between parent-subsidiary is called Transfer Pricing. Tax Avoidance Using Transfer...

Tax Avoidance, Tax Evasion and Tax Planning

November 23, 2015

There are three different concepts viz. tax avoidance, tax evasion and tax planning. Tax Avoidance means an attempt to reduce tax liability through legal means, i.e. to regulate one’s financial affairs in such a way that one pays the minimum tax imposed by the law. This can...