----- Forwarded Message -----
From: CA. V.M.V.SUBBA RAO <vmvsrao@gmail.com>
To: Kanigalla <kanigalla@hotmail.com>
Sent: Friday, 29 March 2013 12:12 AM
Subject: Circulars on TP Law
From: CA. V.M.V.SUBBA RAO <vmvsrao@gmail.com>
To: Kanigalla <kanigalla@hotmail.com>
Sent: Friday, 29 March 2013 12:12 AM
Subject: Circulars on TP Law
Dear Members,
The CBDT has issued two important Circulars relating to Transfer Pricing law. The first bearing No. 02/2013 dated 26.03.2013 deals with the important issue of when the Profit Split Method can be applied in preference to the TNMM and CUP Methods. The second bearing No. 03/2013 dated26.03.2013 explains the circumstances required to be fulfilled for a development centre engaged in R&D activities to be considered to have "insignificant risk" for purposes of determining the ALP.
Both Circulars are a must-read for all tax professionals engaged in transfer pricing and international tax practice.
Regards,
Best Wishes
CA. V.M.V.SUBBA RAO
Chartered Accountant
Door No.24-2-1885,
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e-Mail: vmvsr@rediffmail.com
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