Importance of far analysis in transfer pricing


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This document details the significance of the FAR (Functions Performed, Assets Employed, and Risks Undertaken) analysis in transfer pricing, using the M/s DIT v/s Morgan Stanley & Co. Inc. Supreme Court of India case. It explains how the FAR analysis was crucial in determining arm's length pricing for services provided between related entities. The case highlights that a robust transfer pricing analysis, considering FAR, can prevent the attribution of further profits to a Permanent Establishment (PE). This resource is valuable for tax professionals and businesses involved in international taxation.

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DOCX 21 KB 1 downloads Income Tax
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THIS IS A CASE LAW OF MORGAN STANLEY CO IN SUPREME COURT OF INDIA AND INSIDE THIS YOU WILL SEE WHY FAR ANALYSIS IS SO IMPORTANT IN TRANSFER PRICING #docx
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