Wednesday, July 29, 2020

Transfer pricing in India: Issues and Challenges

What is transfer pricing? 

Transfer pricing is the price paid by the foreign parent company or foreign entity to the local

 When it was introduced in India? 

 Transfer pricing introduced in 2001 in India

 What is the current mark up to the local companies by their parent companies like Google, IBM, and Microsoft? 

14-16%

 

What is Arms length pricing? 

This is international standard pricing method in which the price of the parent company to their local parts compared with independent entities. 

 

What are major areas of transfer pricing? 

Advertising, marketing, and promotion expenses(AMP) 

Some of the AMP expenses are

A. Increasing the brand value of MNC by its subsidary in India. For example, expenses incurred for increasing brand value of Unilever by Hindustan Unilever limited. 

B. Creation of supply chain

Example: Cost of developing distribution network in India by Vodafone. 

C. Conducting market research in India

Illustration: Coca-Cola cola marke research on Diet coke in India. 

Issues

 

1. These are not included in the international transactions. 

Intra group transactions
Centralized procurement. 
Location savings