transfer pricing

This query is : Resolved 

25 November 2016 will TP aplly on dividend received from a wholly owned foreign subsidiary??? and if it wil apply what wil b the method of TP???

25 November 2016 Hi,

On plain reading of section 92B it is quite clear that declaration of Dividend does not come under the purview of the term "International Transaction". Dividend is distribution of after tax profits. The dividend received shall be taxable in the hands of the domestic company and shall be taxed at the rate of 15%. The same can be taken as deduction while the domestic company pays dividend u/s 115-O

Warm Regards
Karthik V Kulkarni,ACA



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