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Applicability of Transfer Pricing

Transfer Pricing Services play a critical role in ensuring that cross-border and specified domestic transactions comply with armu2019s length principles under Indian tax laws. Proper transfer pricing reduces litigation risks, prevents penalties, and supports transparent financial reporting. SKMC Global assists businesses with end-to-end Transfer Pricing Services, including benchmarking analysis, documentation, policy design, and compliance under Sections 92 to 92F of the Income-tax Act. Our experts also support audits, assessments, and dispute resolution.

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Applicability of Transfer Pricing

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  1. APPLICABILITY OF TRANSFER PRICING 1.Transfer pricing provisions apply only where a qualifying international transaction or a specified domestic transaction exists, subject to statutory conditions. 2.An international transaction must be entered into between two or more associated enterprises, where at least one enterprise is a non-resident, in accordance with Section 92B of the Income- tax Act. 3.Transactions that are not international in nature may still attract transfer pricing regulations if they qualify as specified domestic transactions under Section 92BA of the Act. 4.Covered transactions include any expenditure, cost, or interest incurred, as well as the purchase, sale, lease, or transfer of tangible or intangible property, lending or borrowing of funds, or any arrangement having a direct or indirect impact on income, profits, losses, or assets of the enterprises. 5.Under Section 92B(2), transactions with unrelated parties may be deemed international if pricing or terms are influenced by an associated enterprise or governed by a prior agreement. However, as per Section 92(3), transfer pricing provisions shall not apply where their application results in reduction of taxable income in India or increase in reported losses. HOW SKMC GLOBAL CAN HELP? 1.SKMC Global provides end-to-end Transfer Pricing Services, ensuring compliance with Indian regulations and OECD guidelines while minimizing litigation risks. 2.The firm assists in benchmarking and arm’s length price determination, helping businesses justify inter-company pricing with robust economic analysis. 3.SKMC Global supports transfer pricing documentation and reporting, including local file, master file, and prescribed disclosures. 4.Businesses benefit from risk assessment and advisory services, identifying exposure areas in cross-border and domestic transactions. 5.SKMC Global represents clients in transfer pricing audits, assessments, and dispute resolution, ensuring smooth handling before tax authorities. www.skmcglobal.com +91 989-125-5499 info@skmcglobal.com

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