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 [...]
The following points highlight the top six anti-avoidance measures for taxation. The measures are: 1. Exchange of Information 2. Transfer of Tax Residence and Exit Taxes 3. Exchange Controls 4. Branch Profits Tax 5. Use of Tax Havens 6. Anti-EC Directive Shopping Legislation. 1. Exchange of Information: The controls over international tax avoidance and evasion suffer from inadequate information on [...]