Transfer Pricing in India Since Inception to BEPS at Meripustak

Transfer Pricing in India Since Inception to BEPS

Books from same Author: S C Mishra

Books from same Publisher: Wolters Kluwer

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  • General Information  
    Author(s)S C Mishra
    PublisherWolters Kluwer
    Edition2nd Edition
    Publish YearJanuary 2019


    Wolters Kluwer Transfer Pricing in India Since Inception to BEPS by S C Mishra

    The cross-border transaction flows are increasingly being scrutinized mainly because in the present times of fiscal constraints, the tax administrations attempt to secure a wider revenue base. The dynamics of changing business structures and regulatory regimes make the analysis of transfer pricing more challenging for the taxpayers and the tax authorities. In India, there is a growing corpus of case laws on transfer pricing.

    This book covers the discussion on journey of Transfer Pricing from history to Future. The emergence of the provisions of Transfer Pricing, their evolvement to the current stage with the amendments in the law and the future outlook with BEPS are comprehensively discussed, with an outline on its implication on the stakeholders.

    The author has made an endeavor to provide vast commentary on transfer pricing regulations with reference to the judicial pronouncements, not only of India but also which are decided in other geographies like United States, Canada etc. It has been written to make the task of the stakeholders a little easier in complying with the transfer pricing regulations. It covers the discussion on theoretical framework of international business and intra group relations followed by the objects of enquiry into such relations. The implication of BEPS has also been elucidated. It also covers the relevant portions of the OECD and US regulations. The provisions relating to documentation, penalty, risk assessment, audit and Dispute Resolution Mechanism has also been discussed.

    Key Features
    Updated with all the statutory amendments
    Includes discussion on BEPS
    Detailed discussion on digital economy and country by country report
    Covers Safe Harbor Rules and GAAR
    Explicating the determination of Most Appropriate method to ascertain Arm?s length price
    Exploring the concept of Dispute Resolution Panel
    Incorporating more than 250 domestic as well as international judicial pronouncements

    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

    About the Author

    S C Mishra is former Director- General of Income-tax and author of Transfer Pricing Manual. His areas of specialisation include tax policy, capacity building and training. He has wide experience in legislative drafting and amendment of direct tax laws. He has participated in programmes on training methods, tax treaties and comparative tax laws in India and overseas. He has also conducted training programmes on taxation of non-residents. He was involved in designing training programmes for officers of developing countries. As a tax administrator, he investigated into cases of tax frauds comprising also of cross- border transactions. However, the role that he cherishes the most was as a training administrator where his job included identification of training needs, designing course profiles and evaluation of these programmes.