| 1. General |
Client’s answer |
| 1.1 Briefly explain the operational / functional organization structure of the company i.e. Various divisions ( manufacturing, engineering etc.) |
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| 1.2 Details regarding shareholding pattern and the ownership structure to ascertain the Associate Enterprise ( ‘ AE ‘) relationship. |
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| 1.3 Copy of Group Transfer Pricing Policy, if any. |
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| 1.3 Copy of Group Transfer Pricing Policy, if any. |
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| 2. Industry |
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| 2.1 Key competitors |
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| 2.2 Factors influencing pricing |
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| 2.3 A record of the economic and market study, forecasts, budgets or any other financial estimates prepared by the assessee for the business as a whole or for each division or product separately, which may have a bearing on the international transactions entered into by the assessee. |
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| 3. Financials |
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| 3.1 Budget process, including basis of business-wise allocation. |
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| 3.2 Annual report for the year ended March ( for the last three years ). |
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| 3.3 Whether any tax holiday / exemption is availed? |
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| 3.4 Past Tax Position. Whether the company faced any enquiry from the Revenue Authorities on transfer pricing for the financial year ended March. If yes, provide a brief note of the outcome of the above and current status on the same. If possible, provide copy of the relevant orders. |
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| 4. Specific Transaction |
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| 4.1 Nature of products sold |
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| 4.2 Mode of determining the sale price |
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| 4.3 Is the sale price net of export incentives, if any? |
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| 4.4 Explain the process involved and functions performed by the entity of a country and the overseas affiliate in export of finished goods. |
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| 4.5 What are the basic terms and conditions of the contract and the risks assumed by the entity of a country and the overseas affiliate ? Provide a copy of the agreement / contract and the supporting correspondence viz., Invoices, Custom Valuation Report, quotations from third parties ( if any ) etc. |
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| 4.6 Whether the entity of a particular country ( i.e. Tested party) has sold same / similar products to any of the third parties in / outside that particular country. If yes, price charged and terms and conditions for sale of such products. Also provide copy of agreement, if any. |
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| 4.7 Whether the overseas affiliate has purchased same / similar products from any third party in / outside of a particular country (tested party) ? If yes, price charged and terms and conditions for sale of such products. Also provide copy of agreements, if any. |
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