Advance Pricing Agreement

An APA is an agreement that de terminationines in realise an attach tick off of criteria (e.g. method, comparables and appropriate adjustments thereto, as tumefy as critical assumptions as to coming(prenominal) events) for determining the steer legal injurys 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 set agreement so entered. (Direct Taxes Code [the DTC], Sec. 118(3)) In India, the instrument panel will limit the term of an APA to fi ve years (DTC, Sec. 118(4)), The APA process is not an audit, and that should be stated clearly to both innate and remote stakeholders. Bud pass water 2012: Advance pricing agreements to end transfer pricing disputes Mar 10, 2012, 03.58AM IST Tags: * Karishma R Phatarphekar & Shefali Shah| * Grant Thornton India LLP| * DTC| * budget invent of honor| * budget 2012| * APA| * ALP By Karishma R Phatarphekar & The new-fangled ordinal round of transfer pricing (TP) audits in India sawing machine 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 commingle income adjustments do by tax authorities in audits of previous(prenominal) quadruple years. Tax authorities have taken aggressive, incitive and industry-wise positions that have jolted the entire fraternity of the multinational companies (! MNCs). rase to this day, the transfer pricing disputes revolve around very prefatory issues such as use of data not unattached in the public domain, selection of comparables and non-contemporaneous data. Other areas for transfer-pricing disputes are evaluation of shares, integrated guarantees, intercorporate loans, royalty, intangibles, etc, on which there is no statutory guidance. To manage 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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