International Research journal of Management Science and Technology

  ISSN 2250 - 1959 (online) ISSN 2348 - 9367 (Print) New DOI : 10.32804/IRJMST

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INTRODUCTION TO TRANSFER PRICING (INTERNATIONAL CORPORATE TAXATION)

    2 Author(s):  MS. CHARU SINGH, MS. SHASHI SAWHNEY

Vol -  7, Issue- 7 ,         Page(s) : 40 - 44  (2016 ) DOI : https://doi.org/10.32804/IRJMST

Abstract

More than sixty percent of world trade takes place between multinational enterprises. As corporations seek to increase efficiency and competitive advantage by spreading operations across geographical borders to make optimum use of locational advantages and capture new markets, tax authorities worldwide are concerned about preserving their respective tax base. The stated objective of all authorities is ensuring equitable sharing of revenues between jurisdictions. Technological advances coupled with global integration and new business practices add to the challenge of striking this crucial balance. A mismatch between tax jurisdictions exercised by countries may result in double taxation for taxpayers.

1. Taxman books; 
2. First hand Industry Experience, PwC/KPMG/Deloitte/EY website; 
3. ICAI guidelines;
4. Income Tax department of India - http://www.incometaxindia.gov.in/Pages/international-taxation/transfer-pricing.aspx;
5. Income Tax Department's compilation of Transfer Pricing Rules;
6. Domestic Transfer Pricing Overview;
7. Several websites provide overviews of transfer pricing regulations by country, such as the Country References on the TP analytics website;
8. OECD (2010), OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2010, OECD Publishing;
9. Transfer pricing and developing countries, 15. July 2011;
10. Implementation Measures of Special Tax Adjustment (Trial), Guo Shui Fa (2009) No. 2 [Circular 2, as revised] issued by the State Administration of Taxation of the Peoples Republic of China, in Chinese. English translations are available from most of the major accounting firms, and vary slightly. See, e.g., KPMG's version of the complete circular. Hereafter referred to as the Circular or China Circular 2 Art. xx, where xx is the article number of Circular 2.

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