This session is specially designed for working professionals, including lawyers and chartered accountants working in the field of Transfer Pricing. The focus of the webinar is to give a clear understanding of Transfer Pricing basics; its scope and applicability as per the Indian Regulations as well as the OECD framework; and the concept of arm’s length range and multiple-year data. The webinar also touches upon the impact of the COVID environment on Transfer Pricing with suggestions for multinationals and the government to address the situation. The webinar also covers the topic of Transfer Pricing methods; the evolution of these methods in India and an in-depth analysis of the economics underlying these methods. The applicability, benefits, and limitations of the methods are explained at length with the help of examples and case studies that highlight the most contentious issues arising out of the application of these methods. Another essential topic- Transfer Pricing formulation is also covered in this webinar. From explaining the concept and rationale of having a Transfer Pricing policy; the webinar delves its ingredients, its implementation at the transaction level (macro and micro) in a multinational, supply chain management, the concept of significant people functions and intercompany agreements.
Questions asked During the Session:
1. HO in China gives loans to the Project Office in India. Will this be covered under TP?
2. For CUP, It is almost impossible to get the External Comparable Data of the 3rd Party as no one will share its confidential financials. So, only Internal Comparable Data of the AE can be compared.
3. Is CUP the most preferable method as per OECD?
4. While checking TP of 2020, Whether comparable data of 2019 of other co can be used? As comparable data of same year may not be available while doing an audit for 2020
5. If there is no similar industry, what is the best method
6. If Raw material is supplied by Global Supplier in India whereby Contract with the supplier is negotiated by holding company Outside India, then such supplier will be considered as AE
7. The COVID disruption is predominantly in FY 2020-21. So the TP exercise of FY 2020-21 would go with the tested parties' FY 2019-20 in the normal course. So the TP exercise of FY 2021-22 would really be the impactful year from the angle of comparatives. Correct?
8. Sir, why do we generally test the party which has a low-risk profile? (XA over XB))
