Transfer Pricing in India: Principles and Practice covers a gamut of issues relating to the implementation of Transfer Pricing provisions in India. The book will be of immense value to tax practitioners, advocates, chartered accountants, income-tax authorities, taxpayers, researchers, students and every person who deals with or practices or is interested in the transfer pricing provisions under the Income-tax Act,1961.
Key features :
- Explains Transfer Pricing provisions, as amended by the Finance Acts, upto the Finance (No.2) Act, 2019 with the help of legislative intent and history.
- Examines the divergent opinions on TP issues delivered in decisions of appellate tribunals, High Courts and Excerpts from the “OECD-2017- Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrators”.
- Discusses the manner of application and determination of ALP under various TP methods with the help of illustrations.
- Analyses the issues relating to computation of total income in consequence to primary and secondary TP adjustments.
- Includes discussion on specific TP issues related to information technology & technology enables services, financial transactions, intra-group services, cost contribution arrangements and AMP.
- Explains the provisions on Advance Pricing Agreement (APA) scheme, Mutual Agreement Procedure (MAP), Safe Harbour Rules, Appeals and alternative Dispute Resolution Panel and applicable Forms.
- Discusses the impact of provisions of the Multilateral Convention to Implement Tax Treaty Related Measures in relation to MAP and corresponding adjustments.