The document summarizes OECD transfer pricing guidelines for multinational enterprises. It provides background on transfer pricing and its history. It defines key terms like international transactions between associated enterprises which should be conducted at arm's length prices. It describes methods to determine arm's length price like comparable uncontrolled price method. It discusses documentation requirements like local file, master file, and country-by-country reporting that help tax administrations evaluate transfer prices. The conclusion emphasizes the objective of compliance with transfer pricing provisions to allocate profits correctly among countries and avoid shifting of profits.
This Power Point presentation is the latest in the series of GST related slides uploaded by me earlier. This Specifically discusses the Concept of CGST, SGST and IGST. Examples and illustrations have been given to help in understanding.
Ms. Suchitra Kumari has assisted me in editing these slides
Objectives & Agenda :
To know the tolerance range in transfer pricing applicable for Assessment Year 2019-20 notified by CBDT on 13th September, 2019. To understand the conditions for applying tolerance range with relevant illustrations. To analyse the tolerance range notified by CBDT for previous years. Finally, the webinar will also cover the tolerance range in transfer pricing in other Countries.
Legal Framework of TP Provisions (International & Domestic) and Practical Aspect of arriving at Arm’s Length Price (ALP), TP Documentation and Report of Accountants –Form 3CEB’
This ppt describe the Definition of TP with introduction to Transfer pricing and Objectives with types of TP addressed.
Subscribe to Vision Academy YouTube Channel
https://www.youtube.com/channel/UCjzpit_cXjdnzER_165mIiw
This Power Point presentation is the latest in the series of GST related slides uploaded by me earlier. This Specifically discusses the Concept of CGST, SGST and IGST. Examples and illustrations have been given to help in understanding.
Ms. Suchitra Kumari has assisted me in editing these slides
Objectives & Agenda :
To know the tolerance range in transfer pricing applicable for Assessment Year 2019-20 notified by CBDT on 13th September, 2019. To understand the conditions for applying tolerance range with relevant illustrations. To analyse the tolerance range notified by CBDT for previous years. Finally, the webinar will also cover the tolerance range in transfer pricing in other Countries.
Legal Framework of TP Provisions (International & Domestic) and Practical Aspect of arriving at Arm’s Length Price (ALP), TP Documentation and Report of Accountants –Form 3CEB’
This ppt describe the Definition of TP with introduction to Transfer pricing and Objectives with types of TP addressed.
Subscribe to Vision Academy YouTube Channel
https://www.youtube.com/channel/UCjzpit_cXjdnzER_165mIiw
To understand the meaning, need,objective and issues of secondary adjustment and to know the intent of government to introduce secondary adjustment in transfer pricing. Method of secondary adjustment adopted by India. To analyse Union Budget 2019 amendments regarding secondary adjustment. Finally, to know the method of secondary adjustment adopted in other countries.
Helps the student to know about the Agricultural Income in Indian Income tax Act 1961 and also how the Tax Liability will be calculated when an Assessee have both Agricultural and Non Agricultural Income
This is an attempt to explain the broad concept of and rationale behind Transfer Pricing Regulations. Also gives a high level view of the scheme of Indian Transfer Pricing Regulations as on date. Points out the TP controversies in India. Above all gives a well spirited guidance on dealing with TP in India.
To understand the meaning, need,objective and issues of secondary adjustment and to know the intent of government to introduce secondary adjustment in transfer pricing. Method of secondary adjustment adopted by India. To analyse Union Budget 2019 amendments regarding secondary adjustment. Finally, to know the method of secondary adjustment adopted in other countries.
Helps the student to know about the Agricultural Income in Indian Income tax Act 1961 and also how the Tax Liability will be calculated when an Assessee have both Agricultural and Non Agricultural Income
This is an attempt to explain the broad concept of and rationale behind Transfer Pricing Regulations. Also gives a high level view of the scheme of Indian Transfer Pricing Regulations as on date. Points out the TP controversies in India. Above all gives a well spirited guidance on dealing with TP in India.
Andrew Singleton of Baringa has studied and analysed the disruptions and what they mean for utilities and energy trading companies in an insightful presentation delivered last November during ETOT ~ It’s all about adapting to the changes.
"What do you do with your old systems? How do you develop new ones in line with the rising needs? How do you do things differently?"
For more information about the ETOT series, simply visit www.etotsummit.com
Achieving Digitalization in a Document Intensive Energy MarketCTRM Center
As energy companies seek to become more efficient and agile in a rapidly changing marketplace fraught with risks, digitalization - the process of evolving from manual or analog processes to more efficient and cost effective digital processes by reducing the number of times data is touched and ensuring greater accuracy and more rapid movement of data and information throughout the enterprise – continues to attract attention from CIOs across the energy value chain.
Hackathon 3.0 idea Carbon footprint on blockchain with IoTSanjay Talukdar
Idea Owner: Leading role in preparing the business case and low fidelity wireframe for a blockchain & IoT use-case for manufacturing organizations for managing carbon footprint along with a carbon trading platform with a smart contract embedded and presenting in the Hackathon which was selected in the top 10 ideas among a list of 100+ ideas submitted for the Hackathon.
Overview of Transfer Pricing in India - EY IndiaSadanandGahivare
Read about transfer pricing in India & its applicability which can help you build and implement the structure that makes sense for your business & to manage the cost of trade.
Poonawalla Fincorp and IndusInd Bank Introduce New Co-Branded Credit Cardnickysharmasucks
The unveiling of the IndusInd Bank Poonawalla Fincorp eLITE RuPay Platinum Credit Card marks a notable milestone in the Indian financial landscape, showcasing a successful partnership between two leading institutions, Poonawalla Fincorp and IndusInd Bank. This co-branded credit card not only offers users a plethora of benefits but also reflects a commitment to innovation and adaptation. With a focus on providing value-driven and customer-centric solutions, this launch represents more than just a new product—it signifies a step towards redefining the banking experience for millions. Promising convenience, rewards, and a touch of luxury in everyday financial transactions, this collaboration aims to cater to the evolving needs of customers and set new standards in the industry.
What price will pi network be listed on exchangesDOT TECH
The rate at which pi will be listed is practically unknown. But due to speculations surrounding it the predicted rate is tends to be from 30$ — 50$.
So if you are interested in selling your pi network coins at a high rate tho. Or you can't wait till the mainnet launch in 2026. You can easily trade your pi coins with a merchant.
A merchant is someone who buys pi coins from miners and resell them to Investors looking forward to hold massive quantities till mainnet launch.
I will leave the telegram contact of my personal pi vendor to trade with.
@Pi_vendor_247
how to swap pi coins to foreign currency withdrawable.DOT TECH
As of my last update, Pi is still in the testing phase and is not tradable on any exchanges.
However, Pi Network has announced plans to launch its Testnet and Mainnet in the future, which may include listing Pi on exchanges.
The current method for selling pi coins involves exchanging them with a pi vendor who purchases pi coins for investment reasons.
If you want to sell your pi coins, reach out to a pi vendor and sell them to anyone looking to sell pi coins from any country around the globe.
Below is the contact information for my personal pi vendor.
Telegram: @Pi_vendor_247
US Economic Outlook - Being Decided - M Capital Group August 2021.pdfpchutichetpong
The U.S. economy is continuing its impressive recovery from the COVID-19 pandemic and not slowing down despite re-occurring bumps. The U.S. savings rate reached its highest ever recorded level at 34% in April 2020 and Americans seem ready to spend. The sectors that had been hurt the most by the pandemic specifically reduced consumer spending, like retail, leisure, hospitality, and travel, are now experiencing massive growth in revenue and job openings.
Could this growth lead to a “Roaring Twenties”? As quickly as the U.S. economy contracted, experiencing a 9.1% drop in economic output relative to the business cycle in Q2 2020, the largest in recorded history, it has rebounded beyond expectations. This surprising growth seems to be fueled by the U.S. government’s aggressive fiscal and monetary policies, and an increase in consumer spending as mobility restrictions are lifted. Unemployment rates between June 2020 and June 2021 decreased by 5.2%, while the demand for labor is increasing, coupled with increasing wages to incentivize Americans to rejoin the labor force. Schools and businesses are expected to fully reopen soon. In parallel, vaccination rates across the country and the world continue to rise, with full vaccination rates of 50% and 14.8% respectively.
However, it is not completely smooth sailing from here. According to M Capital Group, the main risks that threaten the continued growth of the U.S. economy are inflation, unsettled trade relations, and another wave of Covid-19 mutations that could shut down the world again. Have we learned from the past year of COVID-19 and adapted our economy accordingly?
“In order for the U.S. economy to continue growing, whether there is another wave or not, the U.S. needs to focus on diversifying supply chains, supporting business investment, and maintaining consumer spending,” says Grace Feeley, a research analyst at M Capital Group.
While the economic indicators are positive, the risks are coming closer to manifesting and threatening such growth. The new variants spreading throughout the world, Delta, Lambda, and Gamma, are vaccine-resistant and muddy the predictions made about the economy and health of the country. These variants bring back the feeling of uncertainty that has wreaked havoc not only on the stock market but the mindset of people around the world. MCG provides unique insight on how to mitigate these risks to possibly ensure a bright economic future.
Introduction to Indian Financial System ()Avanish Goel
The financial system of a country is an important tool for economic development of the country, as it helps in creation of wealth by linking savings with investments.
It facilitates the flow of funds form the households (savers) to business firms (investors) to aid in wealth creation and development of both the parties
how to sell pi coins on Bitmart crypto exchangeDOT TECH
Yes. Pi network coins can be exchanged but not on bitmart exchange. Because pi network is still in the enclosed mainnet. The only way pioneers are able to trade pi coins is by reselling the pi coins to pi verified merchants.
A verified merchant is someone who buys pi network coins and resell it to exchanges looking forward to hold till mainnet launch.
I will leave the telegram contact of my personal pi merchant to trade with.
@Pi_vendor_247
USDA Loans in California: A Comprehensive Overview.pptxmarketing367770
USDA Loans in California: A Comprehensive Overview
If you're dreaming of owning a home in California's rural or suburban areas, a USDA loan might be the perfect solution. The U.S. Department of Agriculture (USDA) offers these loans to help low-to-moderate-income individuals and families achieve homeownership.
Key Features of USDA Loans:
Zero Down Payment: USDA loans require no down payment, making homeownership more accessible.
Competitive Interest Rates: These loans often come with lower interest rates compared to conventional loans.
Flexible Credit Requirements: USDA loans have more lenient credit score requirements, helping those with less-than-perfect credit.
Guaranteed Loan Program: The USDA guarantees a portion of the loan, reducing risk for lenders and expanding borrowing options.
Eligibility Criteria:
Location: The property must be located in a USDA-designated rural or suburban area. Many areas in California qualify.
Income Limits: Applicants must meet income guidelines, which vary by region and household size.
Primary Residence: The home must be used as the borrower's primary residence.
Application Process:
Find a USDA-Approved Lender: Not all lenders offer USDA loans, so it's essential to choose one approved by the USDA.
Pre-Qualification: Determine your eligibility and the amount you can borrow.
Property Search: Look for properties in eligible rural or suburban areas.
Loan Application: Submit your application, including financial and personal information.
Processing and Approval: The lender and USDA will review your application. If approved, you can proceed to closing.
USDA loans are an excellent option for those looking to buy a home in California's rural and suburban areas. With no down payment and flexible requirements, these loans make homeownership more attainable for many families. Explore your eligibility today and take the first step toward owning your dream home.
how can i use my minded pi coins I need some funds.DOT TECH
If you are interested in selling your pi coins, i have a verified pi merchant, who buys pi coins and resell them to exchanges looking forward to hold till mainnet launch.
Because the core team has announced that pi network will not be doing any pre-sale. The only way exchanges like huobi, bitmart and hotbit can get pi is by buying from miners.
Now a merchant stands in between these exchanges and the miners. As a link to make transactions smooth. Because right now in the enclosed mainnet you can't sell pi coins your self. You need the help of a merchant,
i will leave the telegram contact of my personal pi merchant below. 👇 I and my friends has traded more than 3000pi coins with him successfully.
@Pi_vendor_247
Exploring Abhay Bhutada’s Views After Poonawalla Fincorp’s Collaboration With...beulahfernandes8
The financial landscape in India has witnessed a significant development with the recent collaboration between Poonawalla Fincorp and IndusInd Bank.
The launch of the co-branded credit card, the IndusInd Bank Poonawalla Fincorp eLITE RuPay Platinum Credit Card, marks a major milestone for both entities.
This strategic move aims to redefine and elevate the banking experience for customers.
How to get verified on Coinbase Account?_.docxBuy bitget
t's important to note that buying verified Coinbase accounts is not recommended and may violate Coinbase's terms of service. Instead of searching to "buy verified Coinbase accounts," follow the proper steps to verify your own account to ensure compliance and security.
how to sell pi coins at high rate quickly.DOT TECH
Where can I sell my pi coins at a high rate.
Pi is not launched yet on any exchange. But one can easily sell his or her pi coins to investors who want to hold pi till mainnet launch.
This means crypto whales want to hold pi. And you can get a good rate for selling pi to them. I will leave the telegram contact of my personal pi vendor below.
A vendor is someone who buys from a miner and resell it to a holder or crypto whale.
Here is the telegram contact of my vendor:
@Pi_vendor_247
how to sell pi coins in all Africa Countries.DOT TECH
Yes. You can sell your pi network for other cryptocurrencies like Bitcoin, usdt , Ethereum and other currencies And this is done easily with the help from a pi merchant.
What is a pi merchant ?
Since pi is not launched yet in any exchange. The only way you can sell right now is through merchants.
A verified Pi merchant is someone who buys pi network coins from miners and resell them to investors looking forward to hold massive quantities of pi coins before mainnet launch in 2026.
I will leave the telegram contact of my personal pi merchant to trade with.
@Pi_vendor_247
2. CONTENTS:
Background & History
Charging Section
Meaning of International Transaction
Associated Enterprises
Arms Length Price
Software
Documentation
Conclusion
3. BACKGROUND
3
GDP
Tax ratio to GDP
Corporate Tax
revenue
ECONOMIC
REFORMS 1991
FDI Inflows
MULTINATIONAL
ENTERPRISES
(MNE’S)
30 % Intragroup
RIGHT PRICE
Transfer Price
WHY TRANSFER
PRICE ?
• 100 to 200 Bn $
• Loss of Tax
revenue
• Slow Growth
• Standard of Living
4. HISTORY
4
OECD
. Improve Global
economy
. Promote World
Trade
Transfer pricing
Guidelines Issued
SECTIONS IN
INCOME TAX
ACT1962
92A. 92B,92C
YEAR 1995 INDIAN CONTEXT
Finance
Act,2001
Prevent erosion
of Taxes in
India
6. SECTION 92 INCOME
TAX ACT : CHARGING
SECTION
International Transaction Between Associated
Enterprises should be at Arms Length Price
7. 7
(Ex:TSAI)
The term “International transactions” refers to transactions
between two (or more) AEs involving the sale, purchase or lease
of tangible or intangible property, the provision of services or
cost-sharing agreements, lending/ borrowing of money or any
other transaction having a bearing on the profits, income, losses
or assets of such enterprises
For a transaction to be an international transaction, it should
satisfy the following two conditions cumulatively:
1) It must be a transaction between two associated enterprises
and
2) At least one of the two enterprises must be a non-resident
Meaning of “International Transaction” (Sec 92B)
9. ASSOCIATED ENTERPRISE 92 A
9
1)SHARE
HOLDING
26% Shares or
Voting Share
2) BOARD OF
DIRECTORS
Appoints more than
half of Board of
Directors
3) LOAN
Loan Given by one
enterprise > 51% of
Total Book value of
Assets of the Other
Enterprise
4) BUSINESS
KNOW HOW
Kia Motors Vs
Hyundai
5) RAW
MATERIALS
90% of Raw
materials
TSAI Ltd
10. ARMS LENGTH PRICE 92 C
10
COMPARABLE
UNCONTROLLABLE
RESALE PRICE COST PLUS PROFIT SPLIT
TRANSACTION
NET MARGIN
Dr Reddy S
Vs.
Novartis ( Ketorol)
Purchase from AE
Transferred to
Unrelated Person .
Reduced Gross Margin
(Ind Distributors)
Cost + Markup in
Similar Transaction
( Use full when Semi
finished goods
transferred b/w AE’S)
Ex : Iron & Steel
PATENTS
PHARMA CO
( Unique &Value
Contribution)
Contribution analysis
Operating Profit Margin
VS Base
Softwares, Pharma
MNES
Ex : Infosys Vs Wipro
Most Appropriate
Method
https://read.oecd-ilibrary.org/taxation/oecd-transfer-pricing-guidelines-for-multinational-enterprises-and-tax-administrations-2022_0e655865-en#page121
11. SOFTWARE'S
11
COMPARABILITY ANALYSIS OF TXN/ NET PROFIT
INDICATORS THROUGH EXTERNAL DATABASE
(MICHAEL PORTERS 5 FORCES – COMPETITION)/ BENCHMARKING/MARKET SHARE)
1) Prowess Tax
2) Capitaline Transfer Pricing Tax
3) TP Genie – BEPS Action point 13 ( Software)-BEPS-8,9,10 -TP
4) Coperitas
5) Thomson Reuters Tax
6) Intra Pricing
7) Royalty Range
Note : BEPS Strategies exploiting gaps and mismatch in Tax Rules
12. DOCUMENTATION ( BEPS -13)
12
LOCAL FILE( 92D)
• TXN > 1Cr
• Local Entity( MSC)
• Controlled TXN( GSICP)
• Financial Information
• Form 3CEB ( TP AUDIT)
MASTER FILE( 92D)
• Overview of Group
• Aggregate Value of
International TXN > 50 Cr
• Group Revenue > 500 cr
• Overview of MNE Group
Business, Intangibles
Policy,
• MNE Intergroup Finance.
COUNTRY BY COUNTRY
REPORT(286)
• Group revenue > 6400 cr
• HUL Case
• Tax Jurisdiction, Revenue,
• PBT, Capital, Employees,
Asset.
https://read.oecd-ilibrary.org/taxation/oecd-transfer-pricing-guidelines-for-multinational-enterprises-and-tax-administrations-2022_0e655865-en#page552
13. SUMMARY
13
Shifting Profits from One country to Other Country
Transfer Price Provisions should be complied by MNES
and these serve as a template for the profit allocation of
inter-company transactions to countries
Professionals ensure that clients are following the Right
Pricing Methods, Documentation as per Section 92D,
286.
Compliance should be main objective of Civil Tax
Penalties.
References :
https://read.oecdilibrary.org/taxation/oecd-transKInkfer-pricing-guidelines-for-multinational-
enterprises-andtax-administrations-2022_0e655865-en#page5