Tag - ALP

International Taxation – Profit Level Indicators

Hello Readers, Hope you have read the previous parts. Click here to see the previous parts. Profit Level Indicators  A profit level indicator (PLI) is selected to test the profitability of tested party. PLIs are ratios that measure relationships between profits and costs incurred or resources employed. PLI should always have an untainted* base (denominator) like adopting cost as base for export transactions and revenue as base for import transactions. *A tainted income or expense would mean one that is received from an AE paid [...]

International Taxation – Int. Transactions, Profit Shifting, ALP Computation

Hello readers, hope you have read the previous parts in which we had covered the basics of international taxation laws and the concept of associated & deemed associated enterprises. Let’s proceed further….. International Transaction An international transaction means: a transaction between two or more associated enterprises, either or both of whom are nonresidents; and transaction in the nature of: sale/ purchase/ lease of tangible property; or sale/ purchase/ lease of intangible property; or provision of services; or lending/borrowing money; or any other [...]

International Taxation – Associated Enterprises

Hello Readers, Yesterday we have discussed about the basics of international taxation and covered basic aspects regarding the Arm Length’s Price principles and the reason behind the introduction of transfer pricing provisions in the Income Tax Act, 1961. Hope you have gone through it. Let’s proceed further and today we will cover other aspects of transfer pricing. **TP means Transfer Pricing **ALP means Arm Length Price Section 92: COMPUTATION OF INCOME FROM TRANSACTION WITH NON-RESIDENT Section 92 provides that any income arising from an “international transaction” [...]

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