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Law Of Transfer Pricing In India
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Download or read book Transfer Pricing written by Mukesh Butani and published by . This book was released on 2007 with total page 1312 pages. Available in PDF, EPUB and Kindle. Book excerpt: Reference guide to the Indian transfer pricing laws and method. The book provides comprehensive coverage and practical guidance on transfer pricing issues, including an analysis of the Indian legislation and transfer pricing methods; documentation requirements; a comparison of the Indian legislation with the OECD guidelines; tax planning techniques related to transfer pricing; discussions of the transfer pricing regime in Australia, Canada, China, France, Germany, Japan, Singapore, the United Kingdom and the United States. Furthermore, it contains brief overviews of the transfer pricing regime in 18 other countries; and the OECD transfer pricing guidelines for multinational enterprises and tax administrations (July 1995).
Book Synopsis Law of Transfer Pricing in India by : D. P. Mittal
Download or read book Law of Transfer Pricing in India written by D. P. Mittal and published by . This book was released on 2015 with total page 1075 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Fundamentals of Transfer Pricing by : Michael Lang
Download or read book Fundamentals of Transfer Pricing written by Michael Lang and published by . This book was released on 2019 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: Transfer pricing continues to be one of the most significant areas of heightened controversy in international taxation for multinational enterprises and tax administrations. Due to its far-reaching consequences, tax professionals and individual tax jurisdictions are required to understand the fundamentals of the topic, which is often caught in a maze of literature. Emerging from the joint research conducted by the WU Transfer Pricing Center at the Institute for Austrian and International Tax Law at WU (Vienna University of Economics and Business), the international tax law firm L&P - Ludovici Piccone & Partners, and the experiences from the annual advanced transfer pricing courses and conferences, this first edition of the book acts as a manual for understanding transfer pricing principles and their practical application. It provides a balanced approach by first detailing the basics of transfer pricing and second proceeding to specific topics that are highly relevant in today's tax environment. In analysing the topics, the work undertaken by the OECD, UN, EU, World Customs Organization, World Bank, International Monetary Fund and other international organizations is considered. Moreover, the book contains several practical examples, judicial precedents and illustrative explanations to complement the understanding.
Book Synopsis Taxmann's Law of Transfer Pricing in India by : D. P. Mittal
Download or read book Taxmann's Law of Transfer Pricing in India written by D. P. Mittal and published by . This book was released on 2009-09-01 with total page 904 pages. Available in PDF, EPUB and Kindle. Book excerpt: ABOUT THE BOOK The Book Deals with Law of Transfer Pricing in India, which Provides for Computation Of Income from International Transactions between Associated Enterprises, having Regard to Arm's Length Price. The Concepts of Arm's Length Price, International Transactions, Associated Enterprises have been Discussed in Detail and Illustrated from Examples Drawn from the Decisions of the Indian and Foreign Courts, OECD Guidelines and US Treasury Regulation and Laws of other Countries. The Procedural Aspects of Determination Of Arm's Length Price and Computation of Income have been Dealt with Exhaustively in View of the Recent Decisions of the Courts and Tribunal in India, Especially in Regard to the Choice of the appropriate method. The Transfer Pricing Obligation of an Assessee in Regard to Making Self-Assessment and Maintenance of Document and Consequences of his Failure have also been Discussed. A Chapter on Interpretative Principles has also been Added.
Book Synopsis Practical Guide to U.S. Transfer Pricing by : Robert T. Cole
Download or read book Practical Guide to U.S. Transfer Pricing written by Robert T. Cole and published by Aspen Publishers. This book was released on 1999 with total page 1302 pages. Available in PDF, EPUB and Kindle. Book excerpt: Practical Guide to U.S. Transfer Pricing is a total approach to U.S. transfer pricing For The complex global marketplace. No book on the market today offers you a more thorough approach to transfer pricing rules that Practical Guide to U.S. Transfer Pricing. The tremendous increase in international trade among the nations of the world has made transfer pricing the most important international tax issues for governments. Thus, it is a major problem for major multinational corporations, which are subject to detriments from transfer pricing rules and adjustments, especially double taxation, penalties, And The cost of compliance. Packed with ready-to-use guidelines, detailed examples, and useful tips, Practical Guide to U.S. Transfer Pricing has been specifically designed to help you make today's transfer pricing rules work for your corporation. The book brings together For The first time, a wealth of features that will empower you to deal quickly and efficiently with all transfer pricing issues and problems. You will find: Unsurpassed coverage of U.S. transfer pricing substantive rules Incisive comparisons of the U.S. rules To The international accepted OECD Transfer Pricing Guidelines Information on both special and traditional procedures for transfer pricing cases Comprehensive explanations of all major transfer pricing methods, such as the Comparable Uncontrolled Price Method, Cost Plus Method, Comparable Profits Methods, and Profit Split Method Criteria for choosing the best transfer pricing method Ideas on how to cope with the U.S. rules in light of foreign requirements A checklist that multinationals can use in developing an international strategy for transfer pricing compliance A full description of the proposed method of global trading of financial products.
Author :S. P. Singh (Of Indian Revenue Service) Publisher :UBS Publishers' Distributors ISBN 13 :9788174763952 Total Pages :246 pages Book Rating :4.7/5 (639 download)
Book Synopsis Transfer Pricing and Regulations for India by : S. P. Singh (Of Indian Revenue Service)
Download or read book Transfer Pricing and Regulations for India written by S. P. Singh (Of Indian Revenue Service) and published by UBS Publishers' Distributors. This book was released on 2002 with total page 246 pages. Available in PDF, EPUB and Kindle. Book excerpt: This Book Analyses Various Aspects Of Transfer Pricing (Tp) In General And The Earlier Provisions In The Indian Law Bearing On Tp In Particular With A View To Evolving A Tp Tax Regulatory Framework For India. It Was Written Prior To The Recent Changes In The Indian Tax Laws Pertaining To Tp. However, The Legislative Framework Suggested Here Should Serve As A Model Against Which The New Law May Be Evaluated.
Book Synopsis Transfer Pricing Law and Practice in India by : Deloitte Touch Tohmatsu India Private Ltd
Download or read book Transfer Pricing Law and Practice in India written by Deloitte Touch Tohmatsu India Private Ltd and published by . This book was released on with total page 806 pages. Available in PDF, EPUB and Kindle. Book excerpt: About the Book "Transfer pricing has come to occupy an important place in the arena of taxation in India in a short time. This has necessitated the need to have a comprehensive understanding of relevant concepts, and awareness of the practical issues involved. Transfer Pricing Law and Practice in India – A fine print analysis seeks to provide these in one place. The book is an exhaustive commentary on the statutory framework of transfer pricing in India and the issues arising thereby, since its introduction in 2001. The Contents have been grouped under various chapters to enable a thorough insight to the reader and to make complex issues easy to comprehend." Features • Elucidation of various concepts of transfer pricing • Practical explanation of administrative mechanism of the regime • Hands on approach on documentation, methods and comparables, with appropriate illustrations • Discussion topical issues arising from recent audits/ assessment • Coverage of recent developments and industry – specific issues • Description of typical transactions and tax optimization structures •Various useful reference materials: FAQs, Global TP Matrix, Case Laws
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 Transfer Pricing in India by : O. P. Yadav
Download or read book Transfer Pricing in India written by O. P. Yadav and published by . This book was released on 2019 with total page 507 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Taxmann’s Transfer Pricing – A Compendium | Collection of incisive & in-depth articles on transfer pricing covered in 2800 Pages by 150 Experts in the form of 75 Articles | Set of 2 Volumes by : The Chamber of Tax Consultants
Download or read book Taxmann’s Transfer Pricing – A Compendium | Collection of incisive & in-depth articles on transfer pricing covered in 2800 Pages by 150 Experts in the form of 75 Articles | Set of 2 Volumes written by The Chamber of Tax Consultants and published by Taxmann Publications Private Limited. This book was released on 2022-03-03 with total page 43 pages. Available in PDF, EPUB and Kindle. Book excerpt: CTC’s Transfer Pricing – A Compendium is a collection of incisive & in-depth articles on transfer pricing, authored by recognised experts in the field. This book promises to provide the necessary guidance and support to fellow professionals to understand the intricate issues, which have always remained contentious and challenging. The current edition of the compendium is updated, incisive, and covers a broader range of topics. Like its previous edition, this book promises to be another handy tool for the following: • Tax Professionals both in India and Overseas • Judiciary and Tax administrators • Readers who want a useful reference point, both for technical analysis and for understanding the proper perspective to view some of the transfer pricing developments of the recent past The Present Publication is the 2022 Edition, covering 75 articles by 150 authors in a comprehensive set of 2 volumes, with the following noteworthy features: • [Covering All Aspects of Transfer Pricing] such as: o Technical Corner including the advanced issues o Legal Corner o Advanced Pricing Agreement (APA) & Mutual Agreement Procedure (MAP) Corner o Industry Corner including 25 sectors o Global Corner including country-wise transfer pricing regulations, the impact of COVID on APA & Dispute resolution, OECD Pillar One & Two • [Understand & Manage Transfer Pricing Risks] This book helps the readers/taxpayers in understanding the complex subject and consequently help them manage their transfer pricing risk effectively • [Authored by 150 Transfer Pricing Experts] The wisdom of eminent authors & their rich experience will be handy for the readers to deal with the complex subject efficiently with a greater degree of confidence • [Practical Examples] The authors, with their immense experience, have extensively covered the subject in greater detail with practical examples Reviewed by Shri S.E. Dastur | Senior Advocate • “… The present publication is in pursuance of the Chamber’s Vision Statement “to contribute to the development of law ... through research, analysis and dissemination of knowledge….” • “… Reference is made, very perceptively and appropriately, to the OECD and UN guidelines on the subject as well as to prevailing international practices, not to mention the latest case laws….” • “… What makes it unique is that it has articles on every conceivable transfer pricing issue authored by over 130 learned professionals (lawyers and chartered accountants) and even some top Revenue officers….” • “… The fact that most of the articles are authored by more than one person ensures that the reader benefits from their collective wisdom on each of the very relevantly chosen subjects….”
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 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.
Book Synopsis International Tax as International Law by : Reuven S. Avi-Yonah
Download or read book International Tax as International Law written by Reuven S. Avi-Yonah and published by Cambridge University Press. This book was released on 2007-09-10 with total page 224 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book explains how the tax rules of the various countries in the world interact with one another to form an international tax regime: a set of principles embodied in both domestic legislation and treaties that significantly limits the ability of countries to choose any tax rules they please. The growth of this international tax regime is an important part of the phenomenon of globalization, and the book delves into how tax revenues are divided among different countries. It also explains how U.S. tax rules in particular apply to cross-border transactions and how they embody the norms of the international tax regime.
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 Taxmann’s Cross-Border Transactions under Tax Laws & FEMA – Practical Commentary covering Income Tax (including International Tax & Transfer Pricing), GST, Customs & FEMA, etc., with Case Laws by : Dr. G. Gokul Kishore
Download or read book Taxmann’s Cross-Border Transactions under Tax Laws & FEMA – Practical Commentary covering Income Tax (including International Tax & Transfer Pricing), GST, Customs & FEMA, etc., with Case Laws written by Dr. G. Gokul Kishore and published by Taxmann Publications Private Limited. This book was released on 2023-05-26 with total page 64 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book provides practical guidance based on judicial interpretation of the law and rules. It also provides an easy-to-understand commentary (with departmental clarifications) on cross-border transactions with respect to the following laws: • Income Tax (including International Tax & Transfer Pricing) • Goods & Services Tax (GST) • Customs • Foreign Exchange Management Act (FEMA) This book will be helpful for practitioners, members of the bar & bench and industry, and assessing officers. The Present Publication is the 3rd Edition, amended by the Finance Act 2023 and updated till 1st May 2023. This book is authored by Dr. Gokul Kishore & R. Subhashree, with the following noteworthy features: • [Easy-to-Understand Practical Commentary] covering: o Income Tax (including International Tax & Transfer Pricing) § Implications of International Transactions § Adoption of Appropriate Transfer Pricing (TP) § Comprehending the Creation of Permanent Establishment (PE) and Double Taxation Avoidance Arrangements (DTAA) § Ensuring Compliance with Withholding Obligations when payment is made to non-resident § Issues relating to Royalty & Fees for Technical Services (FTS), Tax Residency and Foreign Tax Credit (FTC) o GST § Examination of Cross-Border Services by applying Place of Supply & Export of Service provisions under the Integrated Goods and Services Tax Act (IGST), besides analyzing benefits to exporters o Customs § Valuation of Imported Goods under Customs Valuation Rules, when transaction value as declared by importer is not accepted § Availing Customs Duty Exemptions § Duty Remission and Rewards under various Export Promotion Schemes as provided in Foreign Trade Policy 2023 o FEMA § Compliance with Provisions of FEMA on Receipts and Payments for Export and Imports • [Exhaustive Discussion on both Basic Concepts and Issues faced by the Industry] combined with essential commentary on statutory provisions and the jurisprudence. • [Cross-references to other Chapters] wherever implications need to be understood The structure of the book is as follows: • [Chapter 1 | Customs Valuation] discusses Article VII of GATT, Customs Valuation Agreement, Section 14 of Customs Act, 1962, Customs Valuation Rules (for imported goods) and Export Valuation Rules with relevant judgments and orders. Pointers relating to transfer pricing issues have also been mentioned in this chapter • [Chapter 2 | Transfer Pricing] analyzes international transactions, associated enterprises, comparables, methods of determining Arms Length Price, TP challenges in India as per the UN TP Manual and judicial rulings, creation of marketing intangibles and TP issues relating to AMP expenses. TP assessment, adjustment and appellate remedy have also been included. To provide a 360° perspective, secondary adjustment, Country by Country Reporting (CbCr), thin capitalization, Cost Contribution Arrangements, intra-group services and cost-sharing arrangements have been succinctly covered • [Chapter 3 | Permanent Establishment & DTAAs] discusses taxing powers and sources of income. The concept of PE and types of PE have been explained through the relevant articles in various DTAAs, along with treatment by the Indian judiciary and ITAT. The attribution of profits to PE, which has significant practical implications, has also been discussed • [Chapter 4 | Incomes other than Business Income, Withholding Obligations and Foreign Tax Credit] is broad-based and to the extent relevant to cross-border transactions; it provides a commentary laced with practical guidance on residency, the definition of interest, jurisdiction to tax, dividends paid or received, taxation of royalty, FTS, salary, capital gains, other income, withholding obligations, FTC, the requirement to file the return and the concept of the representative assessee • [Chapter 5 | Import & Export under IGST Act] as applicable to import and export of goods, import of services and export of services, along with the provisions on the place of supply and refund mechanism, forms the fifth chapter • [Chapter 6 | Customs Exemption and Export Promotion Schemes under FTP] Considering the relevance to cross-border trade, Customs Duty exemptions and export promotion schemes under Foreign Trade Policy 2023 (FTP) have been discussed in the sixth chapter. • [Chapter 7 | Export and Import under FEMA & Regulations] Knowledge of obligations and provisions applicable to export and import under FEMA and regulations thereunder is integral to cross-border transactions. Therefore, a concise commentary on the same has been provided in Chapter 7 • [Chapter 8 | Dispute Resolution] Dispute resolution mechanisms under IGST Act and Customs Act, along with alternative dispute resolution under Income Tax Act, have been included. Chapter 8 also provides a broad overview of the statutory remedies available to exporters and importers
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 Transfer Pricing, Multinationals and Taxation by : Ashok Kumar
Download or read book Transfer Pricing, Multinationals and Taxation written by Ashok Kumar and published by . This book was released on 2006 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: "Global changes in business and tax environments are having profound impact on the volume and direct trade and transfer pricing strategies. The development of optimal transfer pricing regulations has become a key accounting issue in the context of Indian economy. This book describes and examines various aspects of transfer pricing including import of raw material, other consumable stores, transfer of dividends, royalties, technical fees and other services. It provides an insight into corporate strategies, financial goals and performance evaluation in the context of global and Indian legislations and standards pertaining to transfer pricing. "
