Articles – Page 4

TRANSFER PRICING: A DETAILED STUDY ON DETERMINATION OF ARM’S LENGTH PRICE (ALP) BY MOST APPROPRIATE METHOD (MAM)

India, a global market is emerging everyday with its ever- increasing economic activities and participation of many multi-national groups. Whenever there is an international transaction taking place between two associated enterprises, a market price is set up, known as transfer pricing. When two unrelated enterprises trade with each other, they do so at a market Read More

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Taxability of e-commerce under Service Tax and VAT

Download Transactions done through internet as medium are known as e-commerce. This medium of transmission has made possible international transmission of services that was not possible earlier by the existing modes of transmission, that is, television, fax and phone.

Take Away or Home Delivery of Foods- Decoding the Service Tax Applicability

Food delivery gained prominence in the period of World War II when the Women’s Volunteer Service in the United Kingdom delivered food to homes that had been bombed and ravaged in such a manner.

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

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.

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

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