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Archive for the 'Transfer Pricing' Category



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Further to my earlier article on management fee/transfer fee and the type of management services to be rendered, append below is a very comprehensive list of management services issued by our Malaysian Custom Authorities who is also in charge of the service tax:
(i) Corporate […]

If we noticed that many companies charge management fee as part of the transfer pricing strategy. So what type of services can we name so as to able to justify charging management fee?
Append below are examples that you may considered to draft as management services for charging the management fee. The quantum and justification need […]

a) Comparable Uncontrolled Price (CUP):- This method seeks to determine the ALP by comparing the controlled transaction with the uncontrolled transaction in relation to property transferred or services provided. This method is basically applied to concerns engaged in the manufacturing and selling of the product and hence to be applied to manufacturers.
Typical transactions in respect […]

What we have below

are the terms and definitions used in Transfer Pricing.
the relevant acts pertaining to Transfer Pricing in India.
a sample report from an accountant to be furnished under Section 92E

Transfer Pricing Regulations: are applicable to all enterprises that enter into an “International Transaction” with an “Associated Enterprise“. The objective is to arrive at a […]

India is one of those countries that view Transfer Pricing very seriously, at least amongst Asia Pacific countries. India requires an Annual Certification to accompany the auditor report. As we are fully aware that India is opening up its economies. The authorities would like to ensure that there is no unnecessary hanky-panky by investors to […]



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