Anoop R Chandra & Co

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Increasing participation of multi-national groups in economic activities in the country has given rise to new and complex issues emerging from transactions entered into between two or more enterprises belonging to the same multi-national group. With a view to provide a detailed statutory framework which can lead to computation of reasonable, fair and equitable profits and tax in India, government has incorporated various acts keeping in mind various aspects in this relation.

|In the case of multinational enterprises, the Finance Act, 2001 substituted section 92 with a new section and introduced new sections 92A to 92F in the Income-tax Act, relating to computation of income from an international transaction in relation to the arm's length price, meaning of associated enterprise, meaning of information and documents by persons entering into international transactions and definitions of certain expressions occurring in the said section.
 
Ask yourself?
    Is your company involved in any international transactions with any of its group companies?
    Does your company engage in any inter-company transactions affecting the operating results?
    Does your company render services to/receive services from affiliates free of charge?
    Does your company pay or/ receive charges pertaining to intangibles or cost allocations?
    Has your company been incurring operating losses over the past few years?
    Are you a multinational corporation currently structuring your business plan?
    Are you restructuring global operations as a result of changing global conditions?
       
If your answer is "yes" to one or more of the above questions, your company will in all probability require a transfer pricing review.