Impact of BEPS on transfer pricing documentation (Action 15)

OECD issued the Final Reports on the 15 Action points announced under Base Erosion and Profit Shifting (BEPS) Projectproviding governments with much needed ammunition to close the gaps in the existing international rules that allow corporate profits to “disappear” or be artificially shifted to low/no tax environments, where little or no economic activity takes place … More Impact of BEPS on transfer pricing documentation (Action 15)

BEPS, value creation and transparency

Over several decades and in step with the globalization of the economy, world-wide intra-group trade has grown exponentially. Transfer pricing rules, which are used for tax purposes, are concerned with determining the conditions, including the price, for transactions within a multi-national enterprise (MNE) group resulting in the allocation of profits to group companies in different … More BEPS, value creation and transparency

Transactions in the BEPS world: the road ahead

“Coherence”, “transparency” and “substance” – these words have become the focal point of every discussion surrounding transactions today. In India, the glass ceiling on the importance of these terms was broken a few years ago with the advent of GAAR in the Direct Tax Code and retroactive amendments for taxation of indirect transfers. However, the … More Transactions in the BEPS world: the road ahead

‘Range Concept’ and use of ‘multiple years’ : Better late than Never

The Finance Minister, in his Budget speech in 2014, had announced that range concept for determination of arm’s length price (ALP) will be introduced in the Indian transfer pricing regime where there is adequate number of comparables for determination of ALP. Furthermore, it was announced that use of multiple year data will be permitted for … More ‘Range Concept’ and use of ‘multiple years’ : Better late than Never