With an evolving transfer pricing law in India, certain issues
like Advertisement, Marketing and Promotion (AMP), continue to
trigger arguments amongst the taxpayers and revenue authorities,
which give way to unending debates. In this issue, we cover the
latest judgment, which has deleted the AMP adjustment and has
disregarded AMP as an international transaction. While the debates
continue, the industry still awaits the verdict of the Apex court
to put the AMP issue to rest, and expects guidance on the approach
to be followed for the arm's length price determination.
Apart from this, the other rulings are targeted on the issue of
guarantee fee transaction and intragroup/management fee
transaction. In this edition, under the India Updates, we bring you
the notification released by CBDT, (apex Tax body in India)
providing due date for undertaking Country by Country Report
compliance (CbCR). This notification is applicable in cases where
there has been no arrangement for
