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Transfer Pricing
As business is crossing all geographical boundaries in international arena. Multi-national economic activities has given rise to new and complex issues emerging from transactions entered into between two or more enterprises belonging to the same multi-national group. With a view to provide a detailed statutory framework which can lead to computation of reasonable, fair and equitable profits and tax in respective countries, most of the countries has inducted various statutes keeping in mind various aspects involved.

For example to regulate taxation of multinational enterprises in India, the Finance Act, 2001 substituted section 92 with a new section and introduced new sections 92A to 92F in the Income-tax Act, specifying manner of computation of income from an international transaction in view of the arm's length price, meaning of associated enterprise, meaning of information and documents by persons entering into international transactions and definitions of certain expressions occurring in the said section.
What MNRS Offers
MNRS offers to assist in determining Armís length Price by following several methods viz.
  • Comparable uncontrolled price method;
  • Resale price method;
  • Cost plus method;
  • Profit split method or
  • Transactional net margin method.
Services of MNRS also includes,
  • Advice on the design, structure and management of transfer pricing documentation.
  • Preparation of functionally distinct master documents for different regions, individually tailored to meet local country requirements. This balanced approach accommodates requirements for local comparables with the benefits of a centralized compliance framework in a cost effective manner.
  • Enhanced documentation capabilities with access to multiple databases and the tools for identifying explicit entity types such as toll manufacturers, low risk distributors, and service providers.
  • Project management and monitoring by senior staff.
  • MNRS can help in the development of your in-house competency to manage your transfer pricing needs
Contact for this Service
CA Sandeep Khandelwal
Tel: +91-11-46502975
Telefax: +91-11-29812975
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