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Analyzing Indias Transfer Pricing Disputes
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Book Synopsis Analyzing India's Transfer Pricing Disputes by : Suranjali Tandon
Download or read book Analyzing India's Transfer Pricing Disputes written by Suranjali Tandon and published by . This book was released on 2019 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: Since transfer pricing legislation was introduced in India in 2001, the level of disputes appealed before the Income Tax Appellate Tribunal remains high. This article looks at the data to consider what changes might be introduced to improve the process.
Book Synopsis Resolving Transfer Pricing Disputes by : Eduardo Baistrocchi
Download or read book Resolving Transfer Pricing Disputes written by Eduardo Baistrocchi and published by Cambridge University Press. This book was released on 2012-12-06 with total page 975 pages. Available in PDF, EPUB and Kindle. Book excerpt: Via a global analysis of more than 180 transfer pricing cases from 20 representative jurisdictions, Resolving Transfer Pricing Disputes explains how the law on transfer pricing operates in practice and examines how disputes between taxpayers and tax administrations are dealt with around the world. It has been designed to be an essential complement to the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, which focus on transfer pricing issues but do not refer to specific transfer pricing disputes. All of the transfer pricing cases discussed in the book are linked to the relevant paragraphs of the OECD Guidelines by means of a 'Golden Bridge', namely a table listing the cases according to the paragraphs of the Guidelines to which they refer. It therefore provides examples of the application of the Arm's Length Principle in many settings on all continents.
Book Synopsis An Analysis of Transfer Pricing Disputes in India by : Suranjali Tandon
Download or read book An Analysis of Transfer Pricing Disputes in India written by Suranjali Tandon and published by . This book was released on 2019 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2017 by : OECD
Download or read book OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2017 written by OECD and published by OECD Publishing. This book was released on 2017-07-10 with total page 612 pages. Available in PDF, EPUB and Kindle. Book excerpt: This consolidated version of the OECD Transfer Pricing Guidelines includes the revised guidance on safe harbours adopted in 2013, as well as the recent amendments made by the Reports on Actions 8-10 and 13 of the BEPS Actions Plan and conforming changes to Chapter IX.
Book Synopsis OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2022 by : OECD
Download or read book OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2022 written by OECD and published by OECD Publishing. This book was released on 2022-01-20 with total page 658 pages. Available in PDF, EPUB and Kindle. Book excerpt: In a global economy where multinational enterprises (MNEs) play a prominent role, governments need to ensure that the taxable profits of MNEs are not artificially shifted out of their jurisdiction and that the tax base reported by MNEs in their country reflects the economic activity undertaken therein. For taxpayers, it is essential to limit the risks of economic double taxation.
Book Synopsis A Global Analysis of Tax Treaty Disputes by : Eduardo Baistrocchi
Download or read book A Global Analysis of Tax Treaty Disputes written by Eduardo Baistrocchi and published by Cambridge University Press. This book was released on 2017-08-17 with total page 2216 pages. Available in PDF, EPUB and Kindle. Book excerpt: This two-volume set offers an in-depth analysis of the leading tax treaty disputes in the G20 and beyond within the first century of international tax law. Including country-by-country and thematic analyses, the study is structured around a novel global taxonomy of tax treaty disputes and includes an unprecedented dataset with over 1500 leading tax treaty cases. By adopting a contextual approach the local expertise of the contributors allows for a thorough and transparent analysis. This set is an important reference tool for anyone implementing or studying international tax regulations and will facilitate the work of courts, tax administrations and practitioners around the world. It is designed to complement model conventions such as the OECD Model Tax Convention on Income and on Capital. Together with Resolving Transfer Pricing Disputes (2012), it is a comprehensive addition to current debate on the international tax law regime.
Book Synopsis OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2009 by : OECD
Download or read book OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2009 written by OECD and published by OECD Publishing. This book was released on 2009-08-18 with total page 247 pages. Available in PDF, EPUB and Kindle. Book excerpt: OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations provides guidance on the valuation for tax purposes of cross-border transactions between associated enterprises.
Book Synopsis Transfer Pricing and Dispute Resolution by : Anuschka Bakker
Download or read book Transfer Pricing and Dispute Resolution written by Anuschka Bakker and published by IBFD. This book was released on 2011 with total page 807 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book addresses the complexity, valuation and administrative nuances, and cultural impacts of resolving this significant cross-border issue when tax disputes arise. In recent years, transfer pricing has become in financial terms the most important tax issue faced by multinational companies and tax authorities worldwide. In times of economic downturn, as experienced in recent years, when tax authorities are challenged for revenue, the handling of these issues requires great care, skill, creativity and a true awareness of the ramifications confronting each tax jurisdiction. This book sets out in detail not only the general laws in each tax jurisdiction impacted by the multinational companies' transfer pricing practices, but also the ancillary concerns of how the issue is interpreted locally as well as related to the OECD Guidelines; the varied approaches to administrative resolution of these issues, including specific alternative dispute resolution mechanisms and the effective uses of advance pricing agreements; correlative adjustment procedures in the event of transfer pricing adjustments; cross-border exchange of information concerns; and how to proceed to litigation if all else fails administratively. It is here that the book delves into the specific procedures for litigation in each country which must be evaluated as part of the overall strategy for controversy resolution. Unfortunately, today litigation is on the rise in numerous jurisdictions and the presumption of an administrative resolution is no longer correct. An additional feature of this book is how practical anecdotes are intertwined into the analysis to give the reader a sense of pragmatism for these issues. To this point, there are the various case studies which highlight the technicalities of the local rules, customs, and practices.
Book Synopsis Taxmann's BEPS Implications on Transfer Pricing | Indian Perspective – Comprehensive and Practical Guide with Analysis | Case Studies | Practical Strategies for Tax Professionals by : Ashutosh Mohan Rastogi
Download or read book Taxmann's BEPS Implications on Transfer Pricing | Indian Perspective – Comprehensive and Practical Guide with Analysis | Case Studies | Practical Strategies for Tax Professionals written by Ashutosh Mohan Rastogi and published by Taxmann Publications Private Limited. This book was released on 2024-07-09 with total page 24 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book offers a comprehensive and practical guide to understanding the intricate transfer pricing implications stemming from the Base Erosion and Profit Shifting (BEPS) project within the Indian context. This work culminates two years of extensive research and analysis by a team of transfer pricing experts. The book covers a wide range of topics, starting with an overview of the BEPS project and its objectives. It also includes an analysis of international rulings on BEPS, examining landmark cases and their implications for the transfer pricing landscape. This comprehensive guide is invaluable for tax practitioners, professionals, academics, and business leaders aiming to understand the impact of BEPS recommendations on transfer pricing in India. It facilitates informed discussions on this critical area of taxation and its implications for businesses operating in India. The Present Publication is the Latest Edition, authored by Ashutosh Mohan Rastogi, with the following noteworthy features: • [Realignment of Transfer Pricing Norms] The book explains why BEPS realigned 'Transfer Pricing' norms, illustrated through case studies of Google, Starbucks, and Apple, highlighting their implications on BEPS • [Understanding and Application of BEPS Action Plans] BEPS Action plans have transformed how Transfer Pricing concepts are understood and applied, shifting focus from titles and contracts to functions and risks. This book helps readers understand these nuances in the post-BEPS era • [BEPS Insights on Indian Law] Each chapter provides BEPS insights on Indian Law, discussing BEPS Action plans with reference to Indian Regulations, Circulars, and Case Law and explaining the relevance and implications of BEPS Action points in the Indian context • [Planning for Intangibles in the Post-BEPS World] The book decodes how to attribute profits to intangibles in the BEPS era, explains 'Development, Enhancement, Maintenance, Protection and Exploitation' (DEMPE) functions, and assesses the relevance of holding companies in low-tax havens today • [Economic Ownership] Readers will learn about the importance of Economic Ownership and how it is determined, exploring how Indian law attributes intangible returns based on legal or economic ownership • [Substance in Transfer Pricing] The book discusses the role of substance in Transfer Pricing, exploring whether Transfer Pricing officers can look beyond agreements to uncover reality and the role of significant people functions • [Benchmarking for Financial Transactions] It provides insights on benchmarking for financial transactions such as inter-company loans and guarantees, highlighting the importance of credit rating in financial transaction analysis and how to compute a credit rating • [Location Savings] The book explains where location savings should be taxed and whether profit split is the correct methodology for taxing location savings • [Defending Management Charges] It guides Multinational Enterprises (MNEs) on defending management charges, the availability of Safe Harbour for Management Charges in India, and the shortcomings of the safe harbour • [Cost Contribution Agreements] Readers will understand what cost contribution agreements are and how they differ from intra-group service agreements • [International Rulings on BEPS] The book summarizes leading international rulings on BEPS with illustrations, helping readers understand their implications and how tax litigators can apply them in the Indian context • [Three-Tier Documentation with FAQs] From the evolution and objectives behind the three-tier approach to the requirements suggested by the OECD and their adoption into Indian legislation, the book covers it all. It includes various prescribed templates and answers to general and transaction/issue-specific FAQs addressed by the OECD in the BEPS Action Plan 13 report The detailed contents of the book are as follows: • [Introduction] o This chapter provides an overview of the BEPS project and its objectives, including case studies of companies like Starbucks, Google, and Apple, illustrating the necessity for the BEPS initiative • [BEPS Implications on Transfer Pricing] o This chapter provides an in-depth examination of BEPS implications on transfer pricing, focusing on fundamental changes proposed by the OECD and their potential impact on MNEs in India. It analyses concepts such as economic substance, substance over form, and profit shifting to low-tax jurisdictions • [DEMPE Analysis] o This chapter provides a detailed discussion of the DEMPE (Development, Enhancement, Maintenance, Protection, and Exploitation) functions, highlighting the complexities of attributing profits to intangible assets and the Indian tax authorities approach to these challenges • [BEPS Guidance on 'Substance over Form'] o This chapter discusses the principle of prioritizing economic substance over contractual form, emphasizing the importance of actual business activities and behaviours in determining transfer pricing as per BEPS guidelines • [Low-Value Intra-Group Services] o This chapter examines BEPS guidelines for low value-adding intra-group services, providing simplified approaches for determining arm's length charges and outlining documentation requirements for these services • [Financial Transactions] o This chapter analyses the intricacies of transfer pricing for financial transactions. This chapter covers treasury functions, credit risk assessment, inter-company loans, and guarantees, with an emphasis on compliance with the arm's length principle • [Cost Contribution Arrangements] o This chapter explores the concept of cost contribution arrangements (CCAs) under BEPS, discussing how MNEs share the costs and benefits of joint development activities and the implications for transfer pricing • [Location Savings] o This chapter provides an analysis of location savings and location-specific advantages, offering guidance on how these factors should be incorporated into transfer pricing strategies, particularly in the Indian context • [Three-Tier Documentation] o This chapter provides a review of the BEPS-recommended three-tier documentation approach, including the master file, local file, and country-by-country report, and a discussion on how these documentation requirements are implemented in India • [Dispute Resolution Mechanism] o This chapter discusses the mechanisms for resolving transfer pricing disputes, including the mutual agreement procedure (MAP) and India's Advance Pricing Agreement (APA) program. It provides practical insights into navigating disputes under the new BEPS regime • [International Transfer Pricing Rulings on BEPS] o This chapter summarises significant international transfer pricing rulings related to BEPS, offering key takeaways and their implications for the Indian transfer pricing landscape • [Conclusion] o This chapter concludes by synthesizing the key insights and practical guidance provided in each chapter, reinforcing the importance of understanding and applying BEPS principles to transfer pricing in India
Book Synopsis United Nations Practical Manual on Transfer Pricing for Developing Countries 2017 by : United Nations
Download or read book United Nations Practical Manual on Transfer Pricing for Developing Countries 2017 written by United Nations and published by . This book was released on 2017 with total page 672 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Manual is a response to the need, often expressed by developing countries, for clearer guidance on the policy and administrative aspects of applying transfer pricing (profit shifting) analysis to some of the transactions of multinational enterprises (MNEs) in particular.
Book Synopsis International Taxation by : Nigam Nuggehalli
Download or read book International Taxation written by Nigam Nuggehalli and published by Springer. This book was released on 2019-11-26 with total page 112 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book covers all major topics in international tax law, ranging from permanent establishments and capital gains to the taxation of royalties and technical services, transfer pricing, and General Anti-Avoidance Legislation. It also highlights the Indian “story” of status vs. contract by examining four areas of controversy: permanent establishments, FTS (Fees for Technical Services) & Royalty, capital gains, and transfer pricing. The book approaches the subject of international taxation from two opposing yet related perspectives. One is the tax planning perspective, which involves contracts entered into by individuals and companies; the other is that of state regulation through increasingly complex legislation. The area of permanent establishments demonstrates the dominance of contracts over status, at least with respect to Indian tax law. However, some recent judicial decisions in this area demonstrate the susceptibility of contracts to status-related arguments. The areas of FTS & Royalty as well as those of capital gains and transfer pricing demonstrate the Indian government’s attempts to establish, through legislation, the dominance of status over contracts. Whereas traditional textbooks on international tax law focus on the legal technicalities of tax legislation, this book provides tax scholars and lawyers with an understanding of tax planning and tax legislation side by side in each chapter, specifying the respective kind of actual or anticipated tax planning activity that in turn prompted a legislative response. As such, it offers readers a contextual and practical introduction to the complexities of international tax law, as well as an in-depth analysis of the latest debates and controversies in this area.
Book Synopsis OECD/G20 Base Erosion and Profit Shifting Project Tax Challenges Arising from Digitalisation – Interim Report 2018 Inclusive Framework on BEPS by : OECD
Download or read book OECD/G20 Base Erosion and Profit Shifting Project Tax Challenges Arising from Digitalisation – Interim Report 2018 Inclusive Framework on BEPS written by OECD and published by OECD Publishing. This book was released on 2018-03-16 with total page 218 pages. Available in PDF, EPUB and Kindle. Book excerpt: This interim report of the OECD/G20 Inclusive Framework on BEPS is a follow-up to the work delivered in 2015 under Action 1 of the BEPS Project on addressing the tax challenges of the digital economy.
Book Synopsis The Transfer Pricing Law Review by : Steve Edge
Download or read book The Transfer Pricing Law Review written by Steve Edge and published by . This book was released on 2023 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Decoding Transfer Pricing for Selling Functions by : Rahul K Mitra
Download or read book Decoding Transfer Pricing for Selling Functions written by Rahul K Mitra and published by . This book was released on 2020-08-25 with total page 111 pages. Available in PDF, EPUB and Kindle. Book excerpt: Are some of the theories of OECD and UN around marketing intangibles sacrosanct? The same have been countered through qualitative and quantitative arguments. Quantitative arguments are based upon real life scenarios, with reference to statistical analyses on selected empirical data. Genesis of litigation around marketing intangibles analysed, along with solutions. Concept of royalties for licensed manufacturers explained in the context of regulatory regime of India. Practical solutions provided on harmonisation of transfer pricing and customs duty regulations in complex cases. Concept of attribution of profits to dependent agency permanent establishments explained, with reference to Berry Ratio. Foreword by Dr. Raffalle Dr. Raffaele Petruzzi & Dr. Alfred Storck Professors of Vienna University of Economics and Business
Book Synopsis Asia-Pacific Transfer Pricing Handbook by : Robert Feinschreiber
Download or read book Asia-Pacific Transfer Pricing Handbook written by Robert Feinschreiber and published by John Wiley & Sons. This book was released on 2012-10-03 with total page 558 pages. Available in PDF, EPUB and Kindle. Book excerpt: An overarching look at transfer pricing regimes in Asia-Pacific countries and what they mean for foreign businesses A comprehensive guide for companies doing business globally, Asia-Pacific Transfer Pricing Handbook explains the policies and practices that Asia-Pacific countries employ with regards to taxing foreign businesses. The only book that analyzes and guides companies through the often complex transfer pricing rules in place in Asian-Pacific nations, the book explains how authorities in fifteen countries, including ASEAN, India, New Zealand, Japan, and South Korea, tax any company doing business within their borders. Helping foreign companies to properly price their goods and services for global markets, providing defenses for transfer pricing audits, explaining standards for creating comparables that multijurisdictional tax administrations will accept, explaining documentation requirements and timing issues, and creating awareness about inadvertently becoming a permanent establishment, Asia-Pacific Transfer Pricing Handbook is an essential resource for doing business abroad. Provides comprehensive, accessible information on transfer pricing in Asia-Pacific countries Covers fifteen Asia-Pacific countries, including all ASEAN countries, giving readers unparalleled exposure to the different transfer pricing arrangements across the region Explains how companies doing business abroad should price their goods and services for global markets to remain in accordance with the law A complete and comprehensive guide to transfer pricing and its implications for firms and accountants operating in the Asia-Pacific region, Asia-Pacific Transfer Pricing Handbook explains everything foreign companies need to know about doing business abroad.
Book Synopsis The DEMPE Concept and Intangibles by : Karol Dziwinski
Download or read book The DEMPE Concept and Intangibles written by Karol Dziwinski and published by Kluwer Law International B.V.. This book was released on 2022-06-06 with total page 243 pages. Available in PDF, EPUB and Kindle. Book excerpt: Under the widely applied rules of the OECD Transfer Pricing Guidelines, allocation of the returns from the exploitation of intellectual property should be shared among all entities that contribute towards the profit-generating value of an intangible. This important book, in its detailed treatment of compliance with this principle – known as DEMPE (development, enhancement, maintenance, protection and exploitation) – describes exactly how both taxpayers and tax authorities can achieve an accurate assessment of transactions in order to arrive at an appropriate transfer pricing outcome. Analysing the legal, economic, and business management aspects of multinational enterprises activities, the book provides a comprehensive understanding of the DEMPE concept both in theory and in practice. Fully covered are such issues and topics as the following: role of the DEMPE concept within the framework of international tax law and transfer pricing; interplay of the DEMPE concept with the arm’s length principle; full description of each DEMPE function and analysis in the light of possible tax and transfer pricing consequences; modes of application of the DEMPE concept which can be directly implemented in practice; and additional tools (e.g., value chain analysis or RACI matrix) useful in applying the DEMPE concept. The book also provides the first in-depth analysis of the interplay between the DEMPE concept and the licence model in its various structural variations. Taking into account that intangibles amount to 84% of the market value of the S&P 500 companies and that over 80% of global trade transactions can be linked to value chains of multinational enterprises – and recognizing the scarcity of guidance heretofore on the application of the DEMPE concept – tax advisors, corporate counsels, tax authorities, and academics around the world are sure to appreciate and benefit greatly from this matchless and practical book.
Book Synopsis International Transfer Pricing by : Business International Corporation
Download or read book International Transfer Pricing written by Business International Corporation and published by . This book was released on 1991 with total page 212 pages. Available in PDF, EPUB and Kindle. Book excerpt: A comprehensive guide to corporate practices in internal control and tax compliance. Included are case studies of how firms in a variety of industries approach transfer pricing.
