Bussiness ManagementMBAstrategyHuman ResourceMarketingHospitalityE-commerceInternational Tradingproject managementmedia managementLogisticsFinanceAccountingadvertisingLawBusiness LawEducationEconomicsBusiness Reportbusiness planresearch proposal
英语论文题目英语教学英语论文商务英语英语论文格式商务英语翻译广告英语商务英语商务英语教学英语翻译论文英美文学英语语言学文化交流中西方文化差异英语论文范文英语论文开题报告初中英语教学英语论文文献综述英语论文参考文献
ResumeRecommendation LetterMotivation LetterPSapplication letterMBA essayBusiness Letteradmission letter Offer letter
澳大利亚论文英国论文加拿大论文芬兰论文瑞典论文澳洲论文新西兰论文法国论文香港论文挪威论文美国论文泰国论文马来西亚论文台湾论文新加坡论文荷兰论文南非论文西班牙论文爱尔兰论文
小学英语教学初中英语教学英语语法高中英语教学大学英语教学听力口语英语阅读英语词汇学英语素质教育英语教育毕业英语教学法
英语论文开题报告英语毕业论文写作指导英语论文写作笔记handbook英语论文提纲英语论文参考文献英语论文文献综述Research Proposal代写留学论文代写留学作业代写Essay论文英语摘要英语论文任务书英语论文格式专业名词turnitin抄袭检查
temcet听力雅思考试托福考试GMATGRE职称英语理工卫生职称英语综合职称英语职称英语
经贸英语论文题目旅游英语论文题目大学英语论文题目中学英语论文题目小学英语论文题目英语文学论文题目英语教学论文题目英语语言学论文题目委婉语论文题目商务英语论文题目最新英语论文题目英语翻译论文题目英语跨文化论文题目
日本文学日本语言学商务日语日本历史日本经济怎样写日语论文日语论文写作格式日语教学日本社会文化日语开题报告日语论文选题
职称英语理工完形填空历年试题模拟试题补全短文概括大意词汇指导阅读理解例题习题卫生职称英语词汇指导完形填空概括大意历年试题阅读理解补全短文模拟试题例题习题综合职称英语完形填空历年试题模拟试题例题习题词汇指导阅读理解补全短文概括大意
论文作者:www.51lunwen.org论文属性:作业 Assignment登出时间:2016-03-02编辑:zhaotianyun点击率:18477
论文字数:5637论文编号:org201602292039453731语种:英语 English地区:芬兰价格:免费论文
摘要:摘要:本文主要讲述了印度的监管管理转让定价情况,它提供了成本或费用分配或分配相关的两个或两个以上的企业之间应当在公平价格。
One of the biggest setbacks to the Transfer Pricing regime in India is pending litigation. Recently, many MNCs like IBM, Capgemini and Accenture have come under the scanner of taxmen due to their questionable transfer pricing practices.? Many such disputes go to courts everyday despite the existence of expert alternative panels. Encouraging the use of the DRP mechanism would result in building the image of India as an investor-friendly country. [43]
Another way of tackling this excess litigation is through Advanced Pricing Agreements (APA). At present, India lacks provisions for Advanced Pricing Agreements but the same has been provided for in the Direct Taxes Code Bill. An advanced pricing agreement is a legal agreement between a tax authority and a taxpayer which enables transfer pricing issues to be agreed upon on a prospective basis. Many APAs are also undertaken on a bilateral basis involving two or more tax authorities, where there will be an agreement on how transfer pricing issues are to be resolved between the two tax authorities. These help because they can be crafted to find unique solutions to more complex situations and they provide the taxpayer with certainty of treatment, and, in the bilateral case, can eliminate the problem of double taxation. Many countries in the world have adopted APAs. These arrangements avoid controversies and associated litigation costs [44] ,? hence must be promoted as an ideal setup for India. Fortunately, the Finance Bill, 2012 has proposed the implementation of Advance Pricing Agreements from the 1st of July 2012. Section 92CC is proposed to be inserted into the body of the Act by which the Board can enter into an advance pricing agreement with any person by determining the arm's length price in relation to an international transaction to be entered into by that person. Further, intricacies of advance pricing agreements, similar to those under the DTC Bill of 2010 have been worked out through the proposed provision. If the bill is passed along with the provisions of the APAs, the transfer pricing regime will see the dawn of a new era with negligible pending litigations.
The current legislation defines associated enterprises in Section 92A. After defining through 92A(2), it provides for thirteen circumstances under which a company shall be deemed to be an associated enterprise. Thus, to prove that two companies are associated enterprises of each other, it is essential to prove that they fall under one of the thirteen illustrations envisaged under the provision. [45] ? Thus, the definition of an associated enterprise under the Income Tax Act is a limited and restricted one. This problem also continues into the DTC Bill, 2010. In the opinion of the authors this problem is a major loophole in the Act. A company can easily escape tax liability by proving that it does not fall in any of the illustrations and is therefore not an associated enterprise. Thus, the authors suggest a more comprehensive definition of associated enterprise which is not completely based on illustrations but e本论文由英语论文网提供整理,提供论文代写,英语论文代写,代写论文,代写英语论文,代写留学生论文,代写英文论文,留学生论文代写相关核心关键词搜索。