Transfer pricing_ ae_arm length price

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Querist : Anonymous

Querist : Anonymous (Querist)

12 June 2014 Dear Experts,

Greetings of the day!

Our company is a manufacturing company in the field of oil and Gas. We are approaching one US based institution for certification and monogram purpose in order to have world wide market.

Now my query is due to our dependence on said US based institution, shall we and US institution become AE's as per Sec92A(2)(g)?

if so, what will be the most appropriate menthod for determining ALP?

Nikhil Kaushik

Nikhil Kaushik (Expert)

13 June 2014 what is the nature of dependence between you and this institution?

Querist : Anonymous

Querist : Anonymous (Querist)

13 June 2014 Nature of dependednce is total dependence. We have to get license from that institution only.

Nikhil Kaushik

Nikhil Kaushik (Expert)

13 June 2014 yes. that should make two of you AE. the appropriate method though may depend on the functions performed and ideally should be captured in profit split method

for pricing please refer https://ec.europa.eu/taxation_customs/resources/documents/taxation/gen_info/conferences/andreas_bullen_summary.pdf,

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Querist : Anonymous

Querist : Anonymous (Querist)

13 June 2014 Thanks Sir for your cooperation and timely advise

Nikhil Kaushik

Nikhil Kaushik (Expert)

13 June 2014 you are welcome friend......

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