Transfer Pricing


This query is : Resolved 

22 September 2010 For the purpose of transfer pricing report the amount receivable and payable to associated parties is to be taken as on which date??
Is it correct to mention purchase of corrugated boxes from associated enterprises alongwith purch. of traded finished goods(only boxes were purchased however business is of trading machines)

22 September 2010 All the transaction with Associated Enterprise is to be stated. Whether it is main product or subsidiary product is immaterial. The amount receivable or payable is the total value of the transaction.

Sincerely,

Nilesh Shah

22 September 2010 you r correct sir but my query is that can we show the transactions 4 corrugated boxes(packing material)alongwith transactions of trade goods or disclose it under other head?
another query is that the amount payable or receivable is taken as on 31st March??

23 September 2010 Nilesh Shah writes:

Clause (c) in Form 3CEB has two sub-clauses i.e (i) and (ii). The sub-clauses (i) and (ii) are intimately related. The amount in (i) is required to be compared with (ii).

No effective comparison is possible if in (i) only the figure of receipt/paid or receivable/payable is furnished.

In essence, it means Clause (i) will have the entire figure of the international transaction, whether received or not or paid or not.

The purpose of wording it 'received/receivable' is that even if not a single paise is received, the entire value of the international transaction shall be treated as receivable and shall be reported.

If a part is receivable, yet the entire value of the international transaction shall be reported.

If the entire amount is received, yet the entire value of the international transaction is to be reported, as the amount is received.

The amount can be covered under either of the category i.e. received/receivable. If it is received it will be covered under the category 'received' ; if it is receivable it will be covered under the category 'receivable.'

Sincerely,

Nilesh Shah


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