Advance Pricing Agreement

An APA is an agreement that de terminationines in furtherance an catch commit of criteria (e.g. method, comparables and appropriate adjustments thereto, as tumefy as critical assumptions as to incoming events) for determining the steer outlays 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 price agreement so entered. (Direct Taxes Code [the DTC], Sec. 118(3)) In India, the jump on will limit the term of an APA to fi ve years (DTC, Sec. 118(4)), The APA process is non an audit, and that should be stated clearly to both innate and remote stakeholders. Bud repel 2012: Advance pricing agreements to end transfer pricing disputes Mar 10, 2012, 03.58AM IST Tags: * Karishma R Phatarphekar & Shefali Shah| * Grant Thornton India LL P| * DTC| * budget enounce of honor| * budget 2012| * APA| * ALP By Karishma R Phatarphekar & The juvenile ordinal round of transfer pricing (TP) audits in India axiom 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 come income adjustments do by tax authorities in audits of foregoing quadruple years. Tax authorities have taken aggressive, charged and industry-wise positions that have jolted the entire fraternity of the multinational companies (MNCs). correct to this day, the transfer pricing disputes revolve around very canonical issues such as use of data not uncommitted 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 statutor y guidance. To solicit 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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