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

This book provides a comprehensive commentary on the law relating to Transfer Pricing.

The Present Publication is the 9th Edition, which incorporates all the changes made by the Finance (No. 2) Act, 2019. The 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