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Tokyo, Japan / Dubai, UAE – HLS Global Co., Ltd. (“HLS Global”), a leading international accounting, taxation and business advisory firm, is pleased to announce the expansion of its global presence to the United Arab Emirates (UAE) by incorporating its subsidiary company, HLSGL Management Consultancies LLC, in Dubai (hereinafter referred as “HLS-Global UAE”). The establishment of HLS-Global UAE marks a significant milestone in the firm’s commitment to serving Japanese and multinational companies in the region with excellence.

Indian High Court in a recent decision1 has laid down important principles with regard to selection and application of the most appropriate method for computation of arm’s length price under transfer pricing law of India. BACKGROUND The Indian subsidiary was providing marketing support services to its group companies against receipt of commission at a fixed rate. The consideration received by the Indian subsidiary was benchmarked applying TNMM as the most appropriate method, using Operating Profit / Value Added Expenses (‘OP / VAE’) as the indicator for 2 comparison. The tax officer, however, applied ‘Any Other Method’ for benchmarking the transaction, wherein, he came up with 7 uncontrolled commission agreements and held that the rate at which commission is charged by Indian subsidiary is less than arm’s length rate of commission. The tax officer, accordingly, computed the shortfall / deficit of commission earned by the Indian subsidiary and added in its income. The ‘any other method’ is the sixth method introduced by the Government of India to relax the provision of CUP method which requires actual transactions for comparison; and to consider hypothetical price which would have been charged under comparable uncontrolled conditions as the arm’s length price. The ITAT 3

ASTHOM Partners Collaborates to Strengthen Support for Japanese Companies Globally 法人名 ASTHOM PARTNERS 株式会社  本社所在地 100-0004 東京都千代田区大手町 1-9-5 大手町フィナンシャルシティノースタワー24 階 代表者 虷澤篤志、齋藤俊輔  設立 2022 年 12 月  株式会社 AGS コンサルティングと Hotta Liesenberg Saito LLP の共同出資により設立。  資本金 1,000 万円  事業内容 企業の商標権、著作権、特許権等の知的財産権の取得、管理およびコンサルティング業務等 Web サイト https://asthom.co.jp/ 

ASTHOM PARTNERS Welcomes UK-based Greenback Alan LLP as a New Member ~ Providing Services Across 13 Countries and 35 Locations Worldwide ~ On June 19, 2024, the UK accounting firm Greenback Alan LLP (HQ: Spa Road, London; Managing Partner: Stephen Dabby) joined the global accounting network “ASTHOM PARTNERS”. With this addition, the member firms of ASTHOM PARTNERS now include AGS Consulting Co., Ltd. (HQ: Chiyoda-Ku, Tokyo; Chairman: Atsushi Kanzawa, President: Yoshihide Hirowatari, hereinafter “AGS”), Hotta Liesenberg Saito LLP (HQ: Torrance, California; Global CEO: Shunsuke Saito, hereinafter “HLS”), and Greenback Alan LLP.

A partnership created to empower Japanese companies to expand globally Torrance, CA, U.S.A. / Tokyo, Japan: On December 6, 2022, Hotta Liesenberg Saito LLP (HLS) and AGS Consulting Co., Ltd. (AGS) announced the establishment of a joint venture to provide a wide range of support services to Japanese companies expanding globally. In announcing this significant partnership, the two companies are sharing their vision, spirit, and resources while fully committed to the growth and success of all our clients.

– India’s economic growth estimated at 9.2% to be the highest among all large economies.
– 60 lakh new jobs to be created under the productivity linked incentive scheme in 14 sectors.
– PLI Schemes have the potential to create an additional production of Rs 30 lakh crore.
– Entering Amrit Kaal, the 25 year long lead up to India @100, the budget provides impetus for growth along four priorities: