Tag - transfer pricing

SCN-8 “CONTROLLED FOREIGN COPRORATIONS”

Hello Readers, Welcome to the SCN Series. Today's Term is CONTROLLED FOREIGN COPRORATIONS (CFC): It is an anti tax avoidance measure where a parent company opens a subsidiary in low tax jurisdiction and then evade the tax by non distribution of dividend or profits to the shareholders of parent company. Here it is..... Controlled Foreign Corporations (CFCs) are corporate entities incorporated in an overseas low tax jurisdiction and controlled directly or indirectly by residents of a higher tax jurisdiction (Parent State). Since each corporate entity [...]

SCN-6 “CbC REPORTING”

Hello Readers. Welcome to the SCN Series. Today's term is from International Taxation part of the Income Tax: CbC Reporting: In order to prevent tax avoidance, Multinational Enterprises (MNEs) whose consolidated revenue of International Group is more than Rs. 5,500 crores (as reflected in the consolidated financial statements for the preceding accounting year) are required to report to the income tax department annually for each tax jurisdiction (each country) in which they do business the information set out therein. This reporting is called the Country-by-Country (CbC) Reporting. Click here for the [...]

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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