Law and Practice of Transfer Pricing (Domestic & International Transactions)

As Amended by the Finance Act, 2022
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Description
Transfer pricing as an area of practice has assumed enormous significance given the inherent ambiguous nature of the law and the scope for wide interpretations. The recent decisions by courts and the actions of the Revenue are an indicator of the direction in which this levy is poised. This book aims to simplify the provisions of international and domestic transfer pricing law in India. The book is viewed as an assessee's and practitioner's guide to transfer pricing to facilitate the interpretation and compliance of the legislation. Some of the highlighting features of this book are:
•    Simple and exhaustive coverage of the legal provisions
•    Transfer pricing laws as amended by Finance Act, 2016 have been covered
•    Three sample transfer pricing study reports have been provided to provide a
      practical dimension to documentation
•    More than 900 relevant case laws have been analysed and summarized to provide
     a ready reference for transfer pricing case laws
•    Comparison of safe harbour margins with actual margins through benchmarking analysis
•    The process of benchmarking with recognized databases have been explained by a
     simple step by step approach with screen shots depictions
•    Completed Audit Report Format in Form 3CEB, Safe Harbour Form 3CEFA and
      Form 3CEFB, APA Forms 3CEC and 3CED
•    Practical check list for fulfilling Accountant's responsibility while certifying Form 3CEB
•    Over 70 practical issues faced by the assessee/tax advisors during the course of
     compliance and assessments have been elaborately discussed
•    Significant recent rulings have been briefly analyzed
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Contents
Chapter 1.      Relevance and Rationale of Transfer Pricing
Chapter 2.      Transfer Pricing Law in India
Chapter 3.      Methods for Determining Arm's Length Price
Chapter 4.      Functions, Assets and Risk (FAR) Analysis
Chapter 5.      Benchmarking and Selection of Comparables
Chapter 6.      Domestic Transfer Pricing
Chapter 7.      Transfer pricing for loss-making companies
Chapter 8.      Transfer pricing for specialised capital goods
Chapter 9.      Transfer Pricing Documentation
Chapter 10.    Master File and country-by-country reporting in India
Chapter 11.    Advance Pricing Agreements — An Indian Perspective
Chapter 12.    Mutual agreement procedure
Chapter 13.    Safe Harbour Guidelines with Comparison
Chapter 14.    Action Points on Transfer Pricing and Action Plan 13 - Transfer pricing documentation and
                        country-by-country reporting
Chapter 15.    Form 3CEB and Auditor's Responsibility
Chapter 16.    Interplay of GAAR and transfer pricing
Chapter 17.    Interplay of DTAA and transfer pricing
Chapter 18.    Practical Issues in Transfer Pricing
Chapter 19.    Transfer Pricing Adjustment
Chapter 20.    Recent Developments in Transfer Pricing
Chapter 21.    Range Concept and Multi-year Data
Chapter 22.    Limitation
Chapter 23.    Statutory Provisions, Forms and Updates
Chapter 24.    Transfer Pricing Terminologies and Glossary
Chapter 25.    Un-practical manual on transfer pricing 
Chapter 26.    Impact of Covid-19 on transfer pricing
Chapter 27.    Judicial Precedents
Chapter 28.    Sample Transfer Pricing Report — Case Study 1
Chapter 29.    Sample Transfer Pricing Study Report — Case Study 2
Chapter 30.    Statutory provisions, circulars and notifications
Chapter 31.    Glossary
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Author Details
Shri Divakar Vijayasarathy is a rank holder chartered accountant engaged in international and domestic taxation practice. His core areas of practice are international tax structuring, transfer pricing, tax advisory and tax litigation. He ventured into practice after successful employment stints with leading banks and financial institutions. He is a faculty for the subjects of direct and international taxation for both students and professionals at ICAI and various other professional institutions.
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