Regarding Transfer Pricing

Dear Mr.Verma,

All three companies viz. Indian Parent Company ('IPC'), Dubai Subsidiary Company ('DSC') and Russian Step Down Subsidiary ('RSDS') would be regarded as associated enterprises under section 92A(2) of the Act. However, the international transactions that falls within the purview of Chapter-X would be transaction between IPC and DSC and not transaction between DSC and RSDS.

If transfer price for goods transferred to DSC by IPC founds to be at arm's length then there should not be any issue. A robust documentation may be required to demonstrate that DSC is not used to transfer profits outside India.

If you still have some specific query, you can call me on 9899994934 or mail me at gaurav @ jgarg.com

Best Regards

CA.Gaurav Garg

JGarg Economic Advisors

New Delhi, India