CA Students training on TPO case completed..
MLG team gave detailed training to the CA Final Students of the current batch, on the Transfer pricing assignments and TP cases
this included
- Preparing the TP Study
- use of Capitaline Software
- Use of case studies
- TNMM method
- Meeting the TPO officers of IRS Rank
- Meeting the TPO junior officers of Inspector Ranks
- Discussion on the case
- Pros and Cons of the case
- Choosing the comparables
- excluding the non comparables
- Lot of other things
- Entire TP cycle
- Filing the Replies online
- Using the Income tax portal
Best part of the training was meeting the TPO officers themselves.
for theory see link the website of Govt : https://incometaxindia.gov.in/pages/international-taxation/transfer-pricing.aspx
1.1-‘TRANSFER PRICE” AND “TRANSFER PRICING”
The expression “Transfer Price” is used in the Act in section 92CE and in Explanation to section 92CB of the Income-Tax Act, 1961 (hereinafter referred to as ‘the Act’). The expressions “Transfer Pricing” is used in section 92CA as part of the term “Transfer Pricing Officer”. Though these two terms are used in Chapter X of the Act, they are not defined in the Act. The Income-Tax Rules, 1962 (‘the Rules’) also do not define these terms.
Transfer Price is the actual price charged in a transaction between related entities which are part of the same Multi National Enterprises (MNE) group. The tax rates vary from country to country. So, there is incentive for MNE group to set transfer prices for transactions between its group members such that tax liability for the group as a whole is minimized. This involves setting transfer prices in such a way that less profits are booked in countries with higher tax rates. For example, a company which is a member of group manufactures products in a high tax country. The company would sell them at a low price/ profit to its affiliates/associates in tax haven countries at lower prices/ profits. These prices are lower than the prices that would have obtained had these enterprises been unrelated and dealt at “arm’s length” and erode the tax revenues of the host country. Thus, transfer pricing refers to tax avoidance practiced by MNE groups by setting transfer prices of intra group transactions such that these differ from the prices that would be obtained had the group members been unrelated entities dealing at arm’s length.
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Good thing to learn for all the students and all CA Team members in the MLG Associates. Rollout of IND-AS 101 begins
