Transfer Pricing : An Important Concept in International Taxation
By
Apoorva Anubhuti
Introduction
The rate of growth of International Trade has been catalyzed to a great extent by the emergence and proliferation of Multinational Corporations. The MNCs establish a number of subsidiaries and affiliates all over the world primarily for distribution of their goods and services or for the local manufacture of goods. Prima facie the institution of such subsidiaries globally appears to be a bad management decision due to the huge investment involved for the MNCs in establishing such subsidiaries. This is so as the MNCs could instead have had exclusive dealers or manufacturers locally based in these countries to avoid the huge capital outflow in setting up new subsidiaries. However, under this scenario the MNCs would not be able to accrue the benefits from the abuse of Transfer Pricing which far outweighs the capital and revenue expenditure incurred in establishing, operating these subsidiaries.
Transfer Pricing : What ....