Category: Articles

Indian Transfer Pricing Regulations (TPR) On Advertising, Marketing & Sales Promotion (AMP) Expenses

A disregard of modern capitalism & competitive economics PART I: Introduction To the Concept of Transfer Pricing in relation to AMP The issue of Arm’s Length Pricing (ALP) was first discussed in 1936 in Art. 6 of the League of Nations Draft Convention on the Allocation of Profits and Property of International Enterprises. Later, Art

Disclaimer:  The views and opinions expressed in this article are those of the authors. All data and information provided on this site is for informational purposes only. sapaa.in makes no representations as to accuracy, completeness, correctness or validity of any information on this site and will not be liable for any errors, omissions, or delays in this information or any losses, injuries, or damages arising from its display or use.

Intra-Firm Trade In Service Sector

The essay is quadripartite and it seeks to present a comprehensive discourse on the issue of transfer pricing in intra-firm trade, which has gained currency in today’s global age.
The narrative in the initial section provides an in-depth analysis of the concept of Transfer Pricing against the backdrop of global economics. Firstly, the key terms associated with trans-border intra-firm trade are discussed. This is tied up with a delineation of the relevant OECD guidelines. Thirdly, the information sources for discovering the intra-firm trading activities are briefly dealt with, before ending this section with a short note on the motivations for transfer pricing.

Disclaimer:  The views and opinions expressed in this article are those of the authors. All data and information provided on this site is for informational purposes only. sapaa.in makes no representations as to accuracy, completeness, correctness or validity of any information on this site and will not be liable for any errors, omissions, or delays in this information or any losses, injuries, or damages arising from its display or use.

Permanent Establishments & Double Taxation Avoidance Agreements VIS-A-VIS The Indian Income Tax Act 1961

Plan & Executive Summary The initial section provides a brief discourse on the twin principles of taxation- residence based and source based taxation- and the international stand on the same. Section 2 is tripartite. It continues from the introduction to a PE and firstly, the relevant Indian legal provisions are discussed therein. Secondly, two terms

Disclaimer:  The views and opinions expressed in this article are those of the authors. All data and information provided on this site is for informational purposes only. sapaa.in makes no representations as to accuracy, completeness, correctness or validity of any information on this site and will not be liable for any errors, omissions, or delays in this information or any losses, injuries, or damages arising from its display or use.