CBDT circulars on transfer pricing of contract R&D centres
SHAH, DHINAL ASHVINBHAI
CBDT circulars on transfer pricing of contract R&D centres More questions than answers - 2013 - 95-99
Characterzation of development centers of multinational companies (MNC) in India has been a vexed issue for a considerable time . While the MNCs contend that are contract R&D service providers bearing insignificant or risk free entities, the Transfer pricing officers (TPOs) have been treating them as full or significant risk bearing entities- thus attributing a higher markup for the functional and risk profile borne by them.
TAXATION
336.2
CBDT circulars on transfer pricing of contract R&D centres More questions than answers - 2013 - 95-99
Characterzation of development centers of multinational companies (MNC) in India has been a vexed issue for a considerable time . While the MNCs contend that are contract R&D service providers bearing insignificant or risk free entities, the Transfer pricing officers (TPOs) have been treating them as full or significant risk bearing entities- thus attributing a higher markup for the functional and risk profile borne by them.
TAXATION
336.2