The Ultimate Guide to Transfer Pricing Methods for Business Success
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Unlock the secrets of transfer pricing and navigate global taxation with confidence. .....
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International Taxation - Overview
Businesses over the globe are exploring opportunities to extend in diverse geographies as globalization becomes crucial. The possibility to become global leaders is what is forcing more and more companies out of their home countries. We, Manish Anil Gupta & Co. is the best International Taxation consultant in India that serves you in every sphere of international taxation.
Serving in multiple jurisdictions also produces opportunities to decrease costs and increase market share worldwide. However, the complex laws, including the taxation laws in different territories, can execute overseas expansion time draining and expensive. Whether you are a domestic Indian company contemplating to expand overseas or a foreign company aspiring to invest in India, you must know the laws and regulations that can influence your business strategies and plans. We, the best tax Consultant in West Delhi, have international alliances and have close ties with our foreign affiliates, who possess the technical expertise to help you in navigating through the complex maze of international tax laws worldwide, making us one of the best international tax consultants in India.
Our Service Offerings
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Non-resident Indian (NRI) Taxation in India
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DTAA understanding and framework
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Advice on cross-border transactions
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Advice on prevailing international laws and procedures
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Advice in tax return filings
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Representation before revenue authorities
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Managing international tax litigations
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Advice on various aspects of FEMA
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Foreign Exchange filing and compliances
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Strategise, assess, and evaluate inbound and outbound investments
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Assistance in acquiring relevant regulatory approvals and undertaking compliances
* Withholding tax
Many countries require people paying non-residents to collect the tax due from a non-resident with respect to particular income by withholding such tax from such payments and remitting the tax to the government. Such levies are generally termed withholding taxes. These requirements are induced due to potential difficulties in collecting the tax from non-residents. Withholding taxes are often levied at rates differing from the prevailing Income Tax rates. Further, the withholding rate may vary by type of income or type of recipient. Generally, withholding taxes are charged on the gross amount of income. If the tax withheld from the payment to a person is more than the actual tax payable by such recipient, then the excess tax withheld can be claimed as a refund by filing the Income Tax return.* Treaties
Many nations have entered into tax treaties, also called Double Tax Avoidance Agreements, with other countries to avoid or mitigate double taxation on an income.They tend to have “tie-breaker” clauses for resolving conflicts between residency rules and mechanisms for resolving double taxation disputes on the taxability of incomes.
* Transfer pricing
The practice of charging prices for transferring goods or services between related parties is commonly referred to as transfer pricing. Many countries have become sensitive to the potential for shifting profits with transfer pricing and have adopted rules regulating prices or allowance of deductions or inclusion of income for related party transactions.Arm’s length principle: It is a fundamental concept of most transfer pricing rules that prices levied for a transaction between related enterprises should be those which would be charged for a similar transaction between unrelated parties dealing independently. Different rules prescribe methods for testing whether prices charged for transactions between related parties are at arm’s length price. Examples of such methods include comparable uncontrolled transaction prices, resale prices based on comparable markups, cost plus a markup, and an enterprise profitability method. Such rules generally involve the comparison of related party transactions to similar transactions of unrelated parties.
Manish Anil Gupta & Co. is a renowned international tax consultant in Delhi providing all possible solutions in the area of international taxation in India with its team of experienced professionals. So, if you are looking for international taxation consultants, you can reach us at info@manishanilgupta.com as we are one the best tax consultants in Delhi.
Rahul Pareva
Director-International Taxation and Litigation, ACA
“Confidence Comes From Keeping The Promises You Made To Yourself.” .
Frequently Asked Questions
According to the Liberalised Remittance Scheme (LRS), all resident individuals, including minors, are permitted to freely remit up to US$ 2,50,000 per financial year for any permissible current or capital account transaction or a combination of both.
An Authorised Dealer is any person specifically authorised by the Reserve Bank of India to deal in foreign exchange or foreign securities and usually includes banks.
A person resident in India can own, hold, transfer or invest in a foreign security, foreign currency or any immovable property located outside India if such security, currency or property was acquired, owned or held by such person when he was a resident outside India or inherited from any person who was a resident outside India.
A resident individual can also acquire property and other assets overseas under Liberalised Remittance Scheme.
A resident individual can also acquire property and other assets overseas under Liberalised Remittance Scheme.
An NRI can open the following accounts in India -
* Non-Resident External Account (NRE) Account: It is an Indian rupee-denominated account used to park foreign earnings in India. The deposits in this account are exposed to currency fluctuation.
* Non-Resident Ordinary (NRO) Account: It is also an Indian rupee-denominated account. It is used to manage the income earned in India like dividends, rental income, pension, etc. Tax at 30% (plus applicable surcharge and cess) is deducted at source on interest earned on an NRO account.
* Foreign Currency Non-Residential (FCNR) Account: It is a foreign currency-denominated account and can be opened only in the form of term deposits of 1 to 5 years. Interest income earned on funds in an FCNR account is tax-free in India.
* Non-Resident External Account (NRE) Account: It is an Indian rupee-denominated account used to park foreign earnings in India. The deposits in this account are exposed to currency fluctuation.
* Non-Resident Ordinary (NRO) Account: It is also an Indian rupee-denominated account. It is used to manage the income earned in India like dividends, rental income, pension, etc. Tax at 30% (plus applicable surcharge and cess) is deducted at source on interest earned on an NRO account.
* Foreign Currency Non-Residential (FCNR) Account: It is a foreign currency-denominated account and can be opened only in the form of term deposits of 1 to 5 years. Interest income earned on funds in an FCNR account is tax-free in India.
Yes, a resident individual can make a rupee gift to an NRI who is a close relative of the resident individual. Such amount should be credited to the Non-Resident Ordinary (NRO) A/C of the NRI. However, the gift amount should be within the overall limit of USD 250,000 per financial year as allowed under the LRS for a resident individual. It is the responsibility of the resident donor to make sure that the aggregate amount of all the remittances made by him during a financial year, including the gift amount, does not exceed the limit specified under the Liberalised Remittance Scheme.
Transfer pricing is the practice of charging prices at arm’s length for transferring goods or services between related parties.
Tie-breaker clause in tax treaties are provisions used to resolve conflicts related to residency for tax purposes. Tie-breaker rule is applied when a person is resident in two countries at the same time.
A Permanent Establishment is a fixed place of business that can trigger tax obligations, such as corporate income tax and withholding tax, in a foreign country.
The arm's length principle in transfer pricing refers to pricing transactions between related parties as if they were unrelated parties dealing at arm's length.
Tax treaties, also known as Double Taxation Avoidance Agreements, aim to prevent or reduce double taxation by allocating taxing rights between countries.
A Non-Resident Indian (NRI) is an Indian citizen who resides outside India for a specified duration of time.
International taxation refers to the study and application of tax laws and regulations that govern cross-border transactions, business activities, and the taxation of individuals and entities with international operations.
International taxation helps determine the tax liabilities of individuals and businesses engaged in international transactions, ensures compliance with tax laws, prevents double taxation, and promotes fair and efficient tax systems across countries.
Double taxation occurs when the same income or profits are subject to taxation in more than one jurisdiction. It can be avoided through various mechanisms such as tax treaties, foreign tax credits etc.
Tax treaties are bilateral agreements between countries that provide rules for the taxation of cross-border income and activities. They help allocate taxing rights, eliminate double taxation, and provide mechanisms for cooperation between tax authorities.
