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Transfer Pricing Law and Practice in India Including BEPS - A Fine Print Analysis

Transfer Pricing Law and Practice in India Including BEPS - A Fine Print Analysis

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Description
Globalisation has become a strategic practice for many business organisations in respect of services, manufacturing activities, the recent growth in off-shored business services and development of intangibles. This has brought transfer pricing to the fore-front of international taxation for all stake holders in economic activities - policy makers, business persons and tax consultants. An important development in the recent time has been concerned and expressed by the policy makers in respect of Base Erosion and Profit Shifting (BEPS). The Actions suggested by the international organisations are making paradigm shift in the concepts of international taxation, including transfer pricing. All stake holders must, not only be aware of the developments but take necessary suitable actions. This has necessitated the need to have a comprehensive understanding of relevant concepts, and awareness of the practical issues involved. Transfer Pricing Law and Practice in India including BEPS seeks to provide these at one place. The book embodies an exhaustive commentary on the law as well as recent updates in transfer pricing arena till date. The contents have been grouped under various chapters to enable a thorough insight to the reader and to make complex issues easy to comprehend. An attempt has been made to bridge the gap between theoretical concepts and practical applications of transfer pricing in India. The updated Fifth edition of the book serves within its ambit the salient and topical aspects emanating from the plethora of legal judgments delivered by various Appellate Authorities spread across the country.
Key Features
•    Updated up to the Finance Act, 2017
•    An insight about Three-tiered transfer pricing documentation regime in India
       as well as globally
•    Salient features of BEPS recommendations regarding transfer pricing along with
       conceptual understanding of Action 8, 9 and 10 from Indian standpoint
•    Developing perspective about multilateral instruments recommended under
      Action 15 and its acceptance globally
•    Covers more than 170 case laws exclusively in a separate chapter
•    Pictorial presentation and description on issues interlinked with the concepts of
      International Taxation and Transfer Pricing
•    Typical transactions in relation to loans/ guarantees/business restructuring/
      intangibles have been covered in separate chapters
•    Discerning provisions on secondary adjustment, revision in safe harbour rules
      among Others
•    Discussion on the dispute resolution including the introduction of APA / MAP regime in
       India along with sharing of experiences across industries
•    Understanding amended provisions of domestic transfer pricing
•    Implications of Ind AS adoption on transfer pricing
•    Key highlights on the concept of risk based assessment
•    Useful tools have been drawn in the form of Appendices
•    Detailed discussion on BEPS Action Plan 8, 9 10 & 13 relevant to Transfer Pricing in
       a separate booklet
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Contents
Chapter 1      Transfer Pricing Basics, Regime and Other Related Laws
Chapter 2      Documentation
Chapter 3      Determination of Arm's-length Price
Chapter 4      Selection of Comparables and Adjustments
Chapter 5      Transfer Pricing of Intangibles
Chapter 6      Transfer Pricing and Business Restructuring
Chapter 7      Transfer Pricing of Financial Transactions
Chapter 8      Specified Domestic Transaction
Chapter 9      Audit Issues
Chapter 10    Dispute Resolution
Chapter 11    International Taxation and Transfer Pricing
Chapter 12    Recent Developments in the Transfer Pricing Arena
Chapter 13    Analysis of Landmark Decisions
Chapter 14    Amendments to the Respective Chapters Since 2015 to 2017
Appendix I     Indian Transfer Pricing Regulations
Appendix II    International Data Sources
Appendix III   Transfer Pricing During Adverse Economic Phases
Table of Cases
Index
Contents — Book 2 
Chapter 1    Introduction
Chapter 2    BEPS Project Story so Far
Chapter 3    Overview of Action Plans on Transfer Pricing
Chapter 4    Elucidation of Action Plans on TP from Indian
                       Perspective: Prime Objective and Summary
Chapter 5    Overall Impact BEPS
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Author Details
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