Description
Wolters Kluwer Transfer Pricing In India Since Inception To Beps (Second Edition) by S C Mishra
This is a comprehensive commentary on transfer pricing law in India, comparative OECD guidelines and the US regulations. It contains discussion on OECD Handbook on Effective Implementation of CbC Reporting by developing strategy for stakeholder engagement at the stages of filing, exchange and appropriate use of information. It also contains a new chapter on GAAR and BEPS providing a historical perspective of the doctrine and the case laws from overseas jurisdictions etc.
Table of Contents :-
1 International Business And Intra-Group Relations
2 Objects Of Enquiry Into Intra-Group Business Relations
3 Setting The Transfer Price And The Objects Of Auditing Its Outcome
4 Indian Legislation Relating To Transactions Between Associated Enterprises
5 Arm'S Length Methods
6 Transactional Profit Methods
7 Determination Of Arm'S Length Price By The Most Appropriate Method
8 Safe Harbour Rules And General Anti-Avoidance Rule
9 Comparability
10 Transfer Of Intangible Property
11 Provision Of Intra-Group Services
12 Cost Contribution / Sharing Arrangements / Agreements
13 Intra-Group Financing
14 Business Restructuring
15 Burden Of Proof, Documentation And Penalties
16 Risk Assessment And Audits
17 Dispute Resolution Mechanisms
18 The Journey Ahead
19. General Anti Avoidance Rule And BEPS
20.Realining Taxation With The Location Of Economic Activity