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Transfer Pricing (In relation to International Transactions) (As amended by Finance Act 2015) (2 Volume Set)

Transfer Pricing (In relation to International Transactions) (As amended by Finance Act 2015) (2 Volume Set)

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Description
Tax evasion and tax avoidance are the basic problems faced by the revenue authorities of most of the countries of the world. This problem has become more acute due to globalisation and digitisation of the economy. Transfer pricing is one of the main reasons.
Though transfer pricing is relevant for all transactions, but it is more associated with transactions between close relative and associated concerns. It is general belief that commercial transactions between close relative and associates particularly between different parts of a multinational group may not be subject to the  same market forces, shaping relations between two independent firms. Hence, specific provisions have been made by most of the countries of the world to value transactions between associates concern based on arm's length principle/price. To ensure that the tax base of a multinational enterprise is divided fairly, it is important that transfers within a group should approximate those which would be negotiated between independent firms. This 'arm's length principle' is set out in article 9 of the UN and OECD Model Tax Convention. Earlier, transfer pricing was one of the most important tools of tax planning/avoidance in the hands of taxpayers. But, now the position has changed. It has now become a tool of tax collection in the hands of tax officials. But the measures and methods adopted to tackle it are regressive, particularly in developing countries where the market conditions are not perfect. Transfer pricing is neither a science nor an art but an estimation/valuation of transactions based on "ifs" and "buts". In most of the small cases, it is just penalising for a crime based on suspicion. Here I am not discussing transfer pricing aspects, which have been discussed thoroughly in this book, but will discuss role of various stakeholders, who directly or indirectly are concerned with transfer pricing.
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Contents
Volume One
Part 1 - Basics of Transfer Pricing
Chapter 1 :  Basics of Transfer Pricing
Part 2 - Jurisdiction And Scope
Chapter 2 :  What is a Transaction
Chapter 3 :  Share Transactions
Chapter 4 :  Lending, Borrowing and Guarantee Transactions
Chapter 5 :  Trader and Commission Agent
Chapter 6 :  Cost Sharing or Cost Contribution or Intra Group Services
Chapter 7 :  Reimbursements
Chapter 8 :  Royalty Payments
Chapter 9 :  Advertisement, Marketing and Promotion [AMP) Expenses
Chapter 10 :  Misc. Transactions
Chapter 11 :  Meaning and Scope of Associated Enterprise
Chapter 12 :  One or More Enterprise should be Non Resident
Chapter 13 :  Scope of Transfer Pricing
Chapter 14 :  Dispute over Jurisdictional Issues under TP
Part 3 - Computational Provisions - Transfer Pricing Method
Chapter 15 :  Comparable Uncontrolled Price Method
Chapter 16 :  Cost Plus Method
Chapter 17 :  Resale Price Method
Chapter 18 :  Transactional Net Margin Method - Basics
Chapter 19 :  Transactional Net Margin Method - Profit Level Indicator
Chapter 21 :  Other Method
Chapter 22 :  Most Appropriate Method (MAM)
Volume Two
Part 4 - Computational Provisions - Comparability Analysis
Chapter 23 :  ALP Determination
Chapter 24 :  Single or Multiple Transactions
Chapter 25 :  Single or Multiple Year Data for Comparison
Chapter 26 :  External Comparables
Chapter 27 :  FAR Analysis
Chapter 28 :  Use of Quantitative and Qualitative Filter
Chapter 29 :  Comparability Adjustment
Chapter 30 :  Safe Harbour Rules
Chapter 31 :  Taxpayer and AE's Income/Loss Adjustments
Part 5 - Audit And Assessment
Chapter 32 :  Audit and Return Filing
Chapter 33 :  Burden of Proof
Chapter 34 :  Documentation Requirement
Chapter 35 :  Assessment by AO
Chapter 36 :  Audit by TPO
Chapter 37 :  Dispute Resolution Panel
Chapter 38 :  Penalties and Prosecution
Part 6 - Dispute Resolution Mechanism
Chapter 39 :  TP Dispute Resolution Mechanism
Part 7 - Dispute Resolution - Preventive Provisions
Chapter 40 :  Authority for Advance Ruling (AAR) and TP Disputes
Chapter 41 :  Advance Pricing Arrangement
Chapter 42 :  Safe Harbour - Sector specific rules
Part 8 - Statutory Provisions
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