The second edition of Transfer Pricing Audit Practices in India attempts to disentangle the complex web of transfer pricing controversies. Indian tax administration with its fifteen years of transfer pricing audit adjustments has realized that the pro-revenue positions will not stand the test of law. This book is based on Indian transfer pricing audit experiences for the period ranging from 2003-04 till date, right from TPO to appellate authorities, thereby proving guidance to the tax authorities, taxpayers and tax professionals on technical issues and compliance. Domestic transfer pricing rules and audit approaches shall be helpful for taxpayers. BEPS has been elaborately discussed based on the final report. An insight into the tax audit process and risk based assessment has been dealt with in detail.
The author has drawn from his practical experience of dealing with transfer pricing auditors to provide the taxpayer’s perspective on how to mitigate transfer pricing risk and reduce transfer pricing controversy. The book also highlights the gap in the positions and approach of the tax authorities and taxpayers, and is a good starting point to explore some form of alignment of these positions to ease the pain of taxpayers and potential investors.
- Clarify the technical aspects of transfer pricing
- Present practical, on-the-ground facts during transfer pricing audits
- Explain some of the relevant court rulings on transfer pricing that taxpayers are able to use in defending their transfer pricing litigation
- Provide solutions for risk mitigation and controversy resolution