Transfer Pricing in the COVID Scenario
We organized a virtual session on “Transfer Pricing” which discussed the impact of current economic situation on the existing cross border arrangements from an Indian and International Tax Regulation perspective. Mr. K. Venkatraman, National Head; Mr. Karthik, Associate Director and Mr. G. Mohammed Rizwan, Deputy Manager, Taxation from ASA & Associates LLP spoke.
Mr. Venkatraman gave a broad overview of the existing transfer pricing arrangements in India. Mr. Karthik spoke about the impact it has on revenue/ expense transactions. He mentioned that due to higher purchase costs, there could be short supply, transportation and storage costs. He also opined that there would be inventory write-offs, rent-lease write-offs, increased fixed capacity costs and retrenchment costs. He listed the financial impacts as – increased credit periods, interests on ECB and corporate guarantees. Mr. Rizwan touched upon about the risk of Permanent Establishment which is the risk posed to the employer due to extended stay of stranded individuals in the country under the present situation. He mentioned that as per ‘Place of Effective Management’ (PoEM) guidelines, the key management personnel could be stranded in India and decisions need to be taken within the country. Mr. Rizwan added that a person stranded in the host country /previous home country would face a risk of dual residency. He further gave details on the extension of due dates for filing returns/ appeals, completion of assessments, safe harbor rules etc.
The programme was attended by participants from various industries. Dr. Bose Nair, Vice President, World Trade Center also spoke.