In the context of transfer pricing provisions in relation to international transactions, what are the factors to be considered while selecting the most appropriate method ?

CS Professional · Advanced Tax Laws and Practice · PYQS · June 2015
In the context of transfer pricing provisions in relation to international transactions, what are the factors to be considered while selecting the most appropriate method ?

Answer & Explanation:

Rule 10C of the Indian Income Tax Rules, 1962 states that, in selecting a most appropriate method, the following factors shall be taken into account namely:- The nature and class of the international transaction; The class or classes of Associated Enterprises entering into the transaction and the functions performed by them taking into account assets employed or to be employed and risks assumed by such enterprises; The availability, coverage and reliability of data necessary for application of the method; The degree of comparability existing between the international transaction and the uncontrolled transaction and between the enterprises entering into such transactions; The extent to which reliable and accurate adjustments can be made to account for differences, if any, between the international transaction and the comparable uncontrolled transactions or between the enterprises entering into such transactions; The nature, extent and reliability of assumptions required to be made in the application of a method.

Topics: Income Tax

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