In this article we will discuss about:- 1. Introduction to Anti-Treaty Shopping 2. Impact 3. OECD Model Treaty and Commentaries 4. Beneficial Ownership Requirement 5. Various Countries 6. Comments. Contents: Introduction to Anti-Treaty Shopping Impact of Treaty Shopping Treaty Shopping under the OECD Model Treaty and Commentaries Beneficial Ownership Requirement Anti-Treaty Shopping in Various Countries Comments on Anti-Treaty Shopping 1. [...]
The following points highlight the top two methods for the determination of arm’s length price. The methods are: 1. Traditional Transaction Methods 2. Transactional Profit Methods. 1. Traditional Transaction Methods: (a) Comparable Uncontrolled Price Method ("CUP"): The price is based on the sale or purchase from an uncontrolled party, or from an uncontrolled transaction of third parties, of identical goods [...]
In this article we will discuss about:- 1. Meaning of Transfer Pricing 2. Transactions Involving Transfer Pricing Issues 3. OECD 4. Guidelines 5. Domestic Tax Law 6. Tax Treaties 7. Various Countries. Contents: Meaning of Transfer Pricing Transactions Involving Transfer Pricing Issues OECD and Transfer Pricing Guidelines on Transfer Pricing Transfer Pricing under Domestic Tax Law Transfer Pricing under Tax [...]