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International Taxation

Global Tax And Business Advisory

With globalization becoming norm of the day, companies are looking to align their global tax position with their overall business strategy, to be competitive and provide value to shareholders, where RBA can help keep tax compliance and tax audit hassle-free for their clients.

Due to tie-up with international tax professionals, RBA helps you manage your business tax compliance and tax audit burden by uncovering opportunities, managing global tax risks and meeting cross-border reporting obligations. Our services include the following:

Structuring with a view to minimize tax liability of Foreign Companies/ Non-resident entities investing in India and planning to do business in India.
Structuring of payment under the provisions of Income Tax Act, and Double taxation avoidance treaty, MLA, with a view to minimize tax liability.
We counsel Clients in developing inbound as well as outbound investment structures which result in tax efficiency during the duration of investment period and also at the time of exit.

International Taxation and Transfer Pricing

Increasing participation of multi-national groups in economic activities in the country and inter group transactions has given rise to new and complex issues emerging from transactions entered in between two or more enterprises belonging to the same multi-national or domestic group. RBA provides professional services to work on such issues and helps maintain take financial decisions. With a view to provide a detailed statutory framework which can lead to computation of reasonable, fair and equitable profits and tax assurance in India, government has incorporated various tax provisions keeping in mind various aspects in this relation.

Transfer Pricing Laws & Rules covers:

- International Transfer Pricing &
- Domestic Transfer Pricing (w.e.f. Financial Year 2012-2013)

International Transfer Pricing:

In the case of multinational enterprises (MNE), the Finance Act, 2001 substituted section 92 with a new section and introduced new sections 92A to 92F in the Income-tax Act, relating to computation of income from an international transaction in relation to the arm's length price, meaning of associated enterprise, meaning of information and documents by persons entering into international transactions and definitions of certain expressions occurring in the said section. RBA is one of the best chartered accountant firm in India which works with its clients conducting international transactions. Maintaining tax compliance in a best possible manner in case of multinational enterprises transactions has made RBA one of the best chartered accountant firm in India.

What is section 92?

RBA worked on understanding the new section introduced in the Finance Act, 2001 for its clients. RBA has put forth its understanding as follows:

Section 92

As substituted by the Finance Act, 2002 states that any income arising from an international transaction or where the international transaction comprise of only an outgoing, the allowance for such expenses or interest arising from the international transaction shall be determined having regard to the arm's length price. The provisions, however, would not be applicable in a case, where the application of arm's length price results in decrease in the overall tax incidence in India in respect of the parties involved in the international transaction.

Armâ€™s Length Price:

In accordance with internationally accepted principles, it has been provided that any income arising from an international transaction or an outgoing like expenses or interest from the international transaction between associated enterprises shall be computed having regard to the arm's length price, which is the price that would be charged in the transaction if it had been entered into by unrelated parties in similar conditions. The arm's length price shall be determined by one of the following methods.

Arm's length priced can be calculated by one of the specified methods:

Comparable uncontrolled price method (CUP);
Resale price method (RPM);
Cost plus method (CPM);
Profit split method (PSM) or
Transactional net margin method (TNMM).

The taxpayer can select the most appropriate method to be applied to any given transaction, but such selection has to be made taking into account the various factors prescribed in the rules.

Domestic transfer pricing:

Specified Domestic Transactions, Under the Income Tax Act 1961:

Transfer pricing regulations have been extended vide Finance Act 2012 to include transactions entered into with domestic related parties or by an undertaking with other undertakings of the same entity for the purposes of section 40A, Chapter VI-A and section 10AA. Domestic transfer pricing provisions are applicable from Financial Year 2012-2013.

All of the compliance requirements relating to transfer pricing documentation, accountant's report, etc shall equally apply to specified domestic transactions as they do for international transactions amongst associated enterprises.

Threshold Limit

The above referred transactions will be regarded as SDT only if the aggregate value of all the above specified transactions exceeds the threshold limit of 5 crore (The Limit of Rs 5 crore is replaced with Rs. 20 crores from the F.Y. 2015-16). All the transactions covered under the six limbs as mentioned above will be regarded as SDT only if the aggregate value of all transactions exceeds threshold of INR 5 crore (Up-to the FY 2014-2015) and INR 20 crores (From FY 2015-16 onwards). If the threshold limit is crossed, the taxpayer will be required to comply with TP requirements with reference to all the transactions regardless of the fact that the value of transactions under one of the limbs may be very small or nominal. Thus, there is no internal threshold for each limb of the definition.

The transactions included in the ambit of section 40A(2)(b) would include expenditure transactions like (illustrative only):

Expenditure on buying goods
Expenditure on procurement of services
Expenditure on interest payments
Expenditure on salary, training services, marketing expenses
Expenditure on purchase of tangible and intangible property
Director's remuneration, commission, sitting fees Group charges
Reimbursement expenditure
Guarantee fee expenditure
This provision operates only on the expenditure side and would not have any impact in the hands of the recipients of such payments with respect to tax assurance. Thus, only the persons/ entities incurring such expenditure would be subject to SDT under this provision and would be required to comply with the relevant transfer pricing compliances during transfer pricing audit.

Services RBA Offer

Transfer Pricing Solutions

We at RBA one of the best chartered accountant firm in India have skilled team of tax practitioners, economists and financial analysts to help take financial decisions provide professional services like tax advisory and tax consultancy, etc who are masters in their fields. They focus on reducing threats and increasing opportunities to enhance corporate performance through proactive transfer pricing planning.

Integration of tax and economics

is one of the most important accounting attributes of our transfer pricing capabilities. This unified approach enables us to develop and implement transfer pricing methodologies that are analytically sound, flexible to deal with â€œreal worldâ€ situations and fully compliant with the transfer pricing regulations. Further, this approach also ensures a creative and dynamic tax assurance planning process for our clients.

Transfer Pricing Planning:

Our team helps in evaluation of alternative business structures from a transfer pricing planning perspective in order to optimize allocation of revenues between group entities assuring financial decisions in support of tax compliance.

Compliance and Documentation:

We at RBA provide assistance in various aspects of transfer pricing documentation preparation and compliance. A transfer pricing study report prepared and supported by sound technical positions significantly reduces the risk of a possible tax assurance contingency.

Controversy Resolution:

As revenue authorities become more aggressive in applying transfer pricing regulations, disputes are likely to arise in response to tax assurance. RBA, best chartered accountant firm provides a range of services such as transfer pricing audit management and assistance in handling competent authority negotiations.

Managing Risk:

RBA assists companies in preparing a defence against possible future inquiries relating tax compliance from revenue authorities by assessing the current transfer pricing policies. The potential risks can then be evaluated and if required, appropriate corrective actions can be implemented. Our global controversy solutions and resources enable our clients to confidently address this dynamic issue with confidence.

Integrated Tax Planning:

RBA is the best chartered accountant firm as it specializes in solutions that provide international businesses with an opportunity to comprehensively assess tax compliance position and drive benefits upwards through the company structure. We combine planning, coordination and execution of tax compliance strategies in order to devise flexible solutions that effectively address business changes.