Transfer Pricing in India Since Inception To BEPS, 2017 by S C Mishra

Transfer Pricing in India Since Inception To BEPS

The cross-border transaction flows are increasingly being scrutinized mainly because in the present times of fiscal constraints, the tax administrations attempt to secure a wider revenue base. The dynamics of changing business structures and regulatory regimes make the analysis of transfer pricing more challenging for the taxpayers and the tax authorities. In India, there is a growing corpus of case laws on transfer pricing.

This book covers the discussion on journey of Transfer Pricing from history to Future. The emergence of the provisions of Transfer Pricing, their evolvement to the current stage with the amendments in the law and the future outlook with BEPS are comprehensively discussed, with an outline on it’s implication on the stakeholders.

The author has made an endeavor to provide vast commentary on transfer pricing regulations with reference to the judicial pronouncements, not only of India but also which are decided in other geographies like United States, Canada etc. It has been written to make the task of the stakeholders a little easier in complying with the transfer pricing regulations. It covers the discussion on theoretical framework of international business and intra group relations followed by the objects of enquiry into such relations. The implication of BEPS has also been elucidated. It also covers the relevant portions of the OECD and US regulations. The provisions relating to documentation, penalty, risk assessment, audit and Dispute Resolution Mechanism has also been discussed.

Key Features

Updated with all the statutory amendments
Includes discussion on BEPS
Detailed discussion on digital economy and country by country report
Covers Safe Harbor Rules and GAAR
Explicating the determination of Most Appropriate method to ascertain Arm’s length price
Exploring the concept of Dispute Resolution Panel
Incorporating more than 250 domestic as well as international judicial pronouncements

Transfer Pricing in India Since Inception To BEPS

Table of Contents

Chapter 1 : International Business and Intra-group Relations

Chapter 2 : Objects of Enquiry into Intra-group Business Relations

Chapter 3 : Setting the Transfer Price and the Objects of Auditing its Outcome

Chapter 4 : Indian Legislation Relating to Transactions between Associated Enterprises

Chapter 5 : Arm’s Length Methods

Chapter 6 : Transactional Profit Methods

Chapter 7 : Determination of Arm’s Length Price by the Most Appropriate Method

Chapter 8 : Safe Harbour Rules and General Anti-Avoidance Rule

Chapter 9 : Comparability

Chapter 10 : Transfer of Intangible Property

Chapter 11 : Provision of Intra-Group Services

Chapter 12 : Cost Contribution/ Sharing Arrangements/ Agreements

Chapter 13 : Intra-Group Financing

Chapter 14 : Business Restructuring

Chapter 15 : Burden of Proof, Documentation and Penalties

Chapter 16 : Risk Assessment and Audits

Chapter 17 : Dispute Resolution Mechanisms

Chapter 18 : The Journey Ahead

Annexure

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