TMI BlogTransfer Pricing - Loan to Subsidiary companiesX X X X Extracts X X X X X X X X Extracts X X X X ..... Indian company had given interest free loan Rs.10.00 crores to its wholly owned subsidiary company in USA towards working capital requirment. Transfer Pricing Officer wants to charge interest at the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rate stated in LIBOR. Is there any way to justify not to charge interest. - Reply By Bakul Gandhi - The Reply = If your facts suggests that as business startegy, instead of entire partly as equity ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... capital contribution by way of shares, this part- investment is made as interest free loan. If this Rs 10 crore had been invested in shares, TPO would not have considered LIBOR. This argument may be ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... supplemented if there are rules and regulations of RBI or of USA which does not permit larger equity holding. Also if the subsidiary has declared any dividend, that fact may also help. - Transfe ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... r Pricing - Loan to Subsidiary companies - Query Started By: - TN Rajendran Dated:- 20-7-2011 Income Tax - Got 1 Reply - Income Tax - Discussion Forum - Knowledge Sharing, reply post by an expert, p ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ersonal opinion Tax Management India - taxmanagementindia - taxmanagement - taxmanagementindia.com - TMI - TaxTMI - TMITax ..... X X X X Extracts X X X X X X X X Extracts X X X X
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