F No. 500/139/2012 Government of India Ministry of Finance Department of Revenue Central Board of Direct Taxes (Foreign Tax and Tax Research-I Division) New Delhi, the 29th June, 2013 Circular No.06 /2013 (amending Circular No.03/2013 dated 26th March,2013) Subject: Circular on conditions relevant to identify development centres engaged in contract R&D services with insignificant risk It has been brought to the notice of CBDT that there is divergence of views amongst the field officers and taxpayers regarding the functional profile of development centres engaged in contract R&D services for the purposes of determining arm’s length price/transfer pricing. In some cases, while taxpayers insist that they are contract R&D service providers with insignificant risk, the TPOs treat them as full or significant risk-bearing entities and make transfer pricing adjustments accordingly. The issue has...
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