Transfer pricing -USA

Rahul Dixit (0 Points)

28 January 2025  

Hi I have opened 1 company in USA which is 100% subsidiary of Indian company. USA company provides manpower services to US customers. The services provided by US company is fully provided by Indian company.

Therefore US company is paying 90% of revenue to Indian company because the manpower  services is provided by Indian company.

Following are the reason-

1.Now whether Indian company is at arms length by taking 90% of its revenue?

2. Can TNMM will be Most appropriate method?

3. Can US company retain only 5% and shift all the revenue to Indian company