000 00876npc a2200157Ia 4500
008 140613s2013 xx 000 0 und d
060 _a336.2
100 _aSHAH, DHINAL ASHVINBHAI
245 _aCBDT circulars on transfer pricing of contract R&D centres
_bMore questions than answers
260 _c2013
300 _a95-99
520 _aCharacterzation 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.
653 _aTAXATION
773 _oP14846
_nM
_921598
_011163
_tCHARTERED ACCOUNTANT
942 _2ddc
_cARTCL
999 _c11812
_d11812