Practical Approach to Arm's Length Pricing

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Description
A Practical Approach to Arm's Length Pricing provides a hands-on and technical guide to niche issues in transfer pricing. The first part of the book delves deep into the challenges faced in arm's length pricing of transactions involving intangibles such as patents, know- how, copyrights, trademarks, exploitation rights and so on. It discusses the nuances of finding the arm's length range of royalty rates, IP transfers, hard-to-value intangibles and marketing intangibles. The second part discusses new reforms in transfer pricing regimes around the world, fair transfer pricing policies in some typical industries, and issues such as comparability adjustments and benchmarking of corporate guarantee transactions. There is a dearth of literature on the practical aspects of transfer pricing practice that A Practical Approach to Arm's Length Pricing seeks to rectify. It discusses methods and models of benchmarking complex transactions, and goes on to demonstrate - step by step- how these methods and models can be used to arrive at the arm's length standard. The nuances arising from assessment and litigation trends have also been highlighted.
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Contents
Chapter 1 : Introduction
Part I. Intangibles
Chapter 2 : Intangible in TP Practice
Chapter 3 : Identification and Accounting of Intangible Assets
Chapter 4 : Issues in Taxation of Intangible Assets
Chapter 5 : Treatment of Intangible under GST
Chapter 6 : Valuation and Benchmarking of Intangible Assets
Chapter 7 : Bencmarking of Royalty Rates on Technology Transfer: Part 1
Chapter 8 : Benchmarking of Royalty Rates on Technology Transfer: part 2
Chapter 9 : Advanced methods of Royalty Calculation
Chapter 10 : Transfer Pricing of Marking Intangible
Chapter 11 : Abusive structures using Intangible and Anti-abuse
Part II. Pestering issues in Transfer Pricing Practice
Chapter 12 : Transfer Pricing Reforms
Chapter 13 : Typical Models in Corporate Transactions
Chapter 14 : Corporate Guarantee Transactions
Chapter 15 : Comparability Adjustments
Appendices
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Author Details
SMARAK SWAIN is Director of Administration in the Department of Revenue, prior to which he was Director of Advance Pricing Agreements in the Ministry of Finance. In this role, he shepherded the transfer pricing policy of India, and its MAP and APA programmes. He has been India's delegate-by-name to OECD's Working Party on Taxation of Multinational Enterprises, and India's lead delegate to OECD's FTA MAP Forum. Smarak graduated from IIT Kharagpur in 2006 and joined the Indian Revenue Service in 2008. He is a postgraduate in taxation and business laws from NALSAR University, Hyderabad, and has a Master's in Public Administration from the Lee Kuan Yew School of Public Policy, National University of Singapore. Smarak has wide experience in tax audit and financial  investigation of multinational corporations, charitable trusts and businesses in the informal sector. He regularly lectures at the National Academy of Direct Taxes of India. He has written 10 books, including the bestsellers Loophole Games: A Treatise on Tax Avoidance Strategies and The Great Indian Fraud.