Transfer price - reg.....

Tax planning 548 views 2 replies

Dear All,

 

I am working in a 100% EOU Software company established in Hyderabad, this is 100% subsidiary to the parent company (US). Our employees will work directly to the parent company clients, currently we are following cost plus method (one of transfer price method) to raise invoices to parent company every month.

 

Example:

 

1.       Salary expenses               :               Rs. 800

2.       Operational expense     :               Rs. 100

3.       Depreciation                      :               Rs. 100

 

Total Expenses                  :               Rs. 1000

 

Add: 20% mark-up on cost           :               Rs. 200

 

Invoice Price                      :               Rs. 1200

 

 

In the above case we are adding 20% profit to the cost and we are paying income tax on the profit, but originally parent company incurring losses and here we are paying taxes to the government, this is extra burden to the company overall.

 

 

So is there any best transfer price method to avoid tax payment as well as to arrive exact profitability of the company.

 

Dear all, please suggest best transfer price method.

 

Thanks in advance for your best support.

 

Regards,

NKR

Replies (2)

HI Kullayi,

If the industry for which your company belongs to is incurring losses, you can use Comparable Uncontrollable Price(CUP) method.

If your parent company has similar kind of transactions with any other company, you can use Internal Comparable as well.

best is use per man month rate instead of markup......... if ITO is trying to do adjustment....tell him that parent company also incurred loss


CCI Pro

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