Transfer Pricing Rules and Practices in India

Summary

With this Special Report, you will gain insight on India's attitudes on cross-border commerce with descriptions of transfer pricing audit issues and experiences by sector, along with full text of government audit directives, regulations and court cases on transfer pricing and permanent establishment issues.

Below are some selected highlights from this Special Report

• India's Transfer Pricing Legislation
• Basic Provision of the Regulations
• Comparable Uncontrolled Price Method
• Profit Split Method
• Comparable Data
• Use of Overseas Data
• Arithmetical Mean v. Range of Prices
• Tax Return Disclosure
• Transfer Pricing Audit Process
• Selection of Taxpayers for Audits
• Failure to Maintain or Submit Documentation
• Status of Transfer Pricing Cases
• Audit Issues by Sector
• Composition of Cost Base
• Classification of High End vs. Low End Services
• Application of Industry Rates
• Captive Service Providers
• Allocation of Management Fees and Common Expenses
• Intangibles

Authors: Samir Gandhi and Vishwanath Kane of Deloitte Haskins & Sells in Mumbai
Published: April 18, 2007