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Transfer pricing adjustments have been a feature of many tax systems since the 1930s. The United States led the development of detailed, comprehensive transfer pricing guidelines with a White Paper in 1988 and proposals in 1990–1992, which ultimately became regulations in 1994. [33]
The transactional net margin method (TNMM) in transfer pricing compares the net profit margin of a taxpayer arising from a non-arm's length transaction with the net profit margins realized by arm's length parties from similar transactions; and examines the net profit margin relative to an appropriate base such as costs, sales or assets.
Exit taxation is also referred to as compensation for the "transfer of the place of business", remuneration for taking over functions, assets, risks and contracts with customers, payment for the take-over of part of the business, remuneration for the transfer of production and sales capabilities or transfer of profit potential. [2] [3]
Direct tax in the form of an income tax was introduced by Sir James Wilson in India in 1860 to overcome the difficulties created by the Indian Rebellion of 1857. [12] The organisational history of the Income-tax Department, however, starts in the year 1922, when the Income-tax Act [4], 1922 gave, for the first time, a specific nomenclature to various Income-tax authorities.
Whereas appropriate transfer pricing of tangible goods can be established by comparison with prices charged for similar goods to unrelated parties, transfer pricing of intangible goods, products of intellectual efforts, rarely has comparable equivalents. Transfer prices then have to be established based on expectations of future income. [16]
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Govt to set up a high-level Committee to interact with industry to bring about changes in tax laws if required; FM Proposes to enhance the scope of income tax settlement commission. Govt proposes to strengthen authority for advance ruling in tax, set up more benches; Transfer pricing regulations for residents and non-residents being done
In 2007, it was suggested that the US Internal Revenue Service use formulary apportionment (actually a hybrid approach: routine return plus residual profit split) in the assessment of federal corporate income tax, believing it would lead to increased tax revenue in the face of a trend for multinational corporations to use transfer pricing to ...