29 October 2012
Can i get a clarity on Domestic transfer pricing. Will the Limit of Rs. 5 crore be applicable partywise or will the same be applicable in aggregation. Sunil
29 October 2012
The following transactions with the aggregate value exceeding INR 50 million (US$ 1 million) are covered.
• Expenditure for which payment is made or to be made to specified domestic related parties. • Transfer of goods or services to/from eligible business (tax holiday undertaking) from/to other business (non-tax holiday undertaking). • Business transactions between eligible business (tax holiday unit) and other person(s) producing more than ordinary profits owing to close connection.
Transactions between the specified persons and also between the inter-unit transactions of taxpayers would be covered. e.g.normal operating transactions, remuneration to directors, allocation of costs, etc.
Therefore domestic transfer pricing is on transaction wise.
Most of Real estate companies will hit by DTP policy.
29 October 2012
So say if the company has following transactions will the Domestic Transfer Pricing be applicable: 1. Directors Remuneration Rs. 1 crore to each of its 6 director 2. Purchase from a Holding Company Rs. 4 crore.
12 November 2013
CA.Anuj Gupta, it will be great if u can elaborate on your reply as Holding co is a separate legal entity & 6 directors are also drawing different remunerations.
CAclubindia
