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.
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