Archive for the ‘TRANSFER PRICING’ Category
TRANSFER PRICING IS AN IMPENDING MAJOR TAX CHALLENGE FOR COMPANIES ESPECIALLY MULTINATIONALS
Recently, one of the big four international accounting firm Ernst & Young has conducted a survey on transfer pricing
According to the survey,
There is a dramatic increase in the scope of Transfer Pricing documentation required by governments with penalties imposed more frequently and at higher levels when multinationals get it wrong.
Governments are constantly searching for tax [...]
November 2, 2009
Tags: Malaysia transfer pricing, TRANSFER PRICING Posted in: TRANSFER PRICING
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WHAT IS ARM’S LENGTH PRINCIPLE AND WHAT ARE THE METHOD TO DETERMINE ARM’S LENGTH
Arm length transaction is a very hot topic in transfer pricing. This article seeks to explain what it means “ at arm length and what are some of the traditional methods to determine “ arm length”
“ At Arm Length” means that a transaction performed within a company must be priced as if carried out between [...]
October 19, 2009
Tags: Arms length, TRANSFER PRICING Posted in: Performance Mgmt, TRANSFER PRICING
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A Comprehensive List of Management Services
CLICK TO THE MAIN PAGE FOR ALL ARTICLES ON SHARED SERVICE CENTRE
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 [...]
October 5, 2006
Tags: Management Services Posted in: Corporate Tax, Shared Service Centre, TRANSFER PRICING
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Drafting/Formulating Management Services As Part of Management Fee/Transfer Pricing Strategy
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 [...]
July 11, 2006
Tags: Management Services, Tranfer pricing, Transfer pricing method Posted in: TRANSFER PRICING
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Transfer Pricing Systems :Methods & Selection(Part C)
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 [...]
March 13, 2006
Tags: India transfer pricing, India transfer pricing system Posted in: ASIA PACIFIC REGION, India, TRANSFER PRICING
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Transfer Pricing System: Definitions & Relevant Acts (Part B)
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 [...]
March 13, 2006
Tags: India transfer pricing, India transfer pricing system Posted in: ASIA PACIFIC REGION, India, TRANSFER PRICING
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Transfer Pricing System: Core Documentation File (Part 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 [...]
March 13, 2006
Tags: India transfer pricing, India transfer pricing system Posted in: ASIA PACIFIC REGION, India, TRANSFER PRICING
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