Law Relating To Transfer Pricing With Transfer Pricing Audit & Multilateral Convention 2019 to Implement BEPS

he key features of this book are as follows:

• Detailed discussion on Transfer Pricing provisions and associated rules
• Clause-wise discussion on Transfer Pricing Audit report
• Analysis of various landmark rulings
• Covering all department communications on TP provisions
• Comparison of various provisions in Tabular format
• Discussion on all compliances related to Transfer Pricing
• This book is divided into five divisions, namely:
• General Principles of Transfer Pricing
• Introduction
• Features of the Transfer Pricing Regime under Chapter X
• Transfer Pricing Provisions of Chapter X – When Applicable to an Assessee
• Transfer Pricing Compliances
• Applicability of Transfer Pricing Provisions to International Transactions
• Who are Associated Enterprises?
• What is International Transaction?
• International Transaction: Purchase, Sale or Lease of Tangible Property
• International Transaction: Intangible Property Transactions
• International Transaction: Borrowing or Lending of Money/Financing
• International Transaction: Provision of Services
• International Transaction: Cost Contribution Agreements
• Business Restructuring or Organisation
• Computation of Arm’s Length Price of International Transactions
• What is Arm’s Length Price
• How to Compute Arm’s Length Price
• Comparability Analysis of International Transactions
• Benchmarking: Comparability Analysis & Comparables
• Understanding Business, Industry and Controlled Transactions
• Examination of Comparability Factors of Controlled Transactions
• Tested Party
• Identification of Comparables
• Data to be used in Comparability Analysis
• What is Comparable Uncontrollable Price (CUP) Method and How to Apply it to Calculate ALP?
• What is Resale Price Method (RPM) and How to Apply it to Calculate ALP?
• What is Cost Plus Method (CPM) and How to Apply it to Calculate ALP?
• What is Profit Split Method (PSM) and How to Apply it to Calculate ALP?
• What is Transactional Net Margin Method (TNMM) and How to Apply it to Calculate ALP?
• Any Other Method – Rule 10AB
• Most Appropriate Method (MAM)
• International Transactions: Determination of ALP for Import of Goods
• International Transactions: Determination of ALP for Interest Free Loan to AEs
• International Transactions Involving Intangibles: Determination of ALP
• International Transactions: When Development Centres in India can be Treated as Contract R&D Service Provider with Insignificant Risk
• International Transactions: Determination of ALP for Indenting Activity
• TP Adjustments, Thin Capitalisation Adjustments & Secondary Adjustments in International Transactions
• Transfer Pricing Adjustments
• Thin Capitalisation Adjustments
• Secondary Adjustments
• Transfer Pricing Procedures
• Power of AO to Compute ALP
• Reference to Transfer Pricing Officer -Section 92CA
• Transfer Pricing Dispute Resolution Mechanism
• Safe Harbour Rules
• Advance Pricing Agreement
• Obligation of Assessee to Maintain Transfer Pricing Documentation
• Audit Report
• Audit Report & Documentation – International Transactions
• Due Date for Filing Return for Assessee Required to Furnish Audit Report u/s 92E – Section 139
• Time Limit for Assessment and Reassessment – Sections 153 and 153B
• Specified Domestic Transaction
• Definition of Specified Domestic Transactions
• Audit Report & Documentation – Specified Domestic Transactions
• Miscellaneous
• Penalty – Sections 271, 271AA, 271BA and 271G