TMI BlogApplication for an Advance Pricing AgreementX X X X Extracts X X X X X X X X Extracts X X X X ..... c. Address of the applicant: d. Address for communication: e. Location(s) of the business enterprises in India: f. Email Id and the contact numbers of the person with whom correspondence is required to be made: g. Names and designation of the authorised representatives who would be appearing before the authorities for negotiations of the APA: 2. Whether pre-filing discussions were sought by the applicant? If yes, please furnish: a. Date of application for pre-filing meeting: b. Date of pre-filin ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... f. Address of Ultimate parent company of applicant: g. Country of residence of Ultimate parent company of applicant: h. Taxpayer Registration Number/ Taxpayer Identification Number/ Functional equivalent/ Any unique number used for identification of the Ultimate parent company by the Government of that country/specified territory of which it claims to be a resident: ; ] 5. a. Are you applying for a Unilateral, Bilateral or Multilateral APA: Unilateral/ Bilateral/ Multilateral b. If you are applying for a Bilateral or Multilateral APA, have the Associated Enterpri ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 11. History and background of the applicant and the associated enterprise: 12. General description of business and products/services: 13. Multinational structure, organizational arrangement, operational set-up, including major transaction flows: 14. Identify all other transaction flows of the multinational enterprise (volumes, directions and amounts) that may have an impact on the pricing of the covered transactions: 15. Functional currency for each entity and the currency which is used for the proposed transactions to be covered under the APA: 16. Accounting and costing ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 21. Copies of all relevant inter-company agreements (pricing, cost sharing, licensing, distributorship etc.): (Please enclose copies) III. Industry and market analyses 22. Detailed industry analysis: a. Comprehensive description of industry as well as generally accepted industrial and commercial practices: b. Identification and general profile of competitors, including respective market shares: c. Industry and general business statistics, financial ratios, and analyses/studies: d. Critical success factors: 23. Detailed ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 30. Provide all information, including detailed analyses and explanations needed to establish the appropriateness of a proposed TPM, in accordance with transfer pricing regulations as contained in the Indian Income-tax law: 31.Discussion and analysis of each transfer pricing method, applied or rejected, for each covered transaction. In particular provide details on accepted or rejected internal comparables. (Indicate assumptions, strategies, and policies that may have influenced the acceptance or rejection of each TPM): 32. Summary of selected TPMs and secondary TPMs, if used as a sanity check: VI. Impact of proposed TPMs ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ted vide Notification No. 36/2012, Dated 30-8-2012 2. Inserted vide Notification No. 23/2015, dated 14-03-2015 3. Substituted vide Not. 53/2017 - Dated 16-6-2017 3. Name(s) of the Associated Enterprises with whom the APA is requested for: 4. Substituted vide Not. 53/2017 - Dated 16-6-2017 4. Name of the country(ies) in which the associated enterprises mentioned in (3) above are located: 5. Substituted vide Notification No. 95/2019 dated 06-11-2019 w.e.f. 01-09-2019 before it was read as Permanent Account Number - Forms Tax Management India - taxmanagementindia - taxmanagement - taxmanagementindia.com - TMI - Tax ..... X X X X Extracts X X X X X X X X Extracts X X X X
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