Tax administrators world over, as also OECD, have come to realise the inherent limitations of traditional transaction methods and in the process Transactional Profit Methods have gained greater acceptance than before. This is evident from the suggested amendments in ‘Transfer Pricing Guidelines for Multinational Enterprises and tax Administrators’ issued by OECD in 1995. They are no longer transfer pricing methods of last resort.
Dr. C. P. Ramaswami analyses the defects of the proposed Direct Tax Code and argues that if this Bill is introduced in Parliament it will be a calamity, and if passed – a disaster.
The article deals with the problems/limitations of taxing transactions entered into over internet that, specially the ones that cut across national boundaries.