Transfer Pricing Advisory | Company Registration Online

About This Plan

With incremental adoption of globalization and rapid growth in several multi-national companies trying to establish their operation facilities, production houses in India, taxation in India is being aligned with global tax practices.

Therefore, it is incredibly important for every business entity to develop a thorough understanding of the transfer pricing regulations applicable on an Indian registered business entity, to plan the way for a business as well as its tax structure.

What is Transfer Pricing?

Transfer pricing generally refers to the price(s) of transactions controlled and practiced between associated enterprises. Such pricing decisions may be taken under conditions differing from independent enterprises.

Transfer pricing is the value attached to transfers of goods, services, and technology between related entities located in different territories. It also refers to the value attached to transfers between unrelated parties which are controlled by a common entity.

In other words, Profits accruing to the parent company can be increased by setting high transfer prices to siphon off profits from subsidiaries registered and operating in high tax countries and low transfer prices to divert profits to subsidiaries located in low-tax jurisdictions.

Why is it mandatory for related parties to document their transfer pricing?

Finance Act, 1994 had introduced section 92A to 92F under the Income Tax Act. This separate code on transfer pricing under Sections 92 to 92F of the Indian Income Tax Act, 1961 covers intra-group cross-border transactions which are applicable from 1st April 2001, and specified domestic transactions which are applicable from 1st April 2012.

The Income Tax Act, 1961 now prescribes that income arising from international transactions or specified domestic transactions between associated enterprises should be computed having regard to the arm’s-length price.

It has been notified that any allowance for an expenditure or interest or allocation of any cost or expense arising from an international transaction or specified domestic transaction also shall be determined having regard to the arm’s-length price.

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