25 November 2012
MY CLIENT IS AN INDIAN COMPANY SUPPLYING CASTING GOODS TO ITS PARENT COMPANY IN USA AFTER PURCHASING FROM LOCAL MARKET AS PER SPECIFICATION OF PARENT COMPANY.WORKING CAPITAL FINANCING IS ALSO PROVIDED BY PARENT COMPANY.PLEASE SUGGEST WHICH IS THE MOST APPROPRITE METHOD TO BE USED FOR TRANSFER PRICE AUDIT PURPOSES. V K JHUNJHUNWALA
to Comment upon the Method of Tranfer Pricing we need to check on a full detail Checklist, then an apt method is Chosen...The Checklist Involves points like: 1. the Agreement to Sell/MOU between two Parts. 2. Profit percentage decided 3. market Conditions and comparable cost and Profit 4. Etc.
After considering all these Points, the method of Transfer PRicing is decided.
please contact me for the Transfer Pricing calculations and Method.
Indian Income Tax Act provides 5 Method for the determination of the arm’s-length price. However no particular method has been accorded a greater or lesser priority. The most appropriate method for a particular transaction would need to be determined having regard to the nature of the transaction, class of transaction, volume of transaction or associated persons and functions performed, Assets employed and risk bear by such persons, as well as other relevant factors.
So without proper information nobody can provide MAM for transfer pricing. So please share full information in this regards