Transfer Pricing Law and Practice in India

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Publisher :
ISBN 13 : 9788184730968
Total Pages : 806 pages
Book Rating : 4.7/5 (39 download)

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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

Transfer Pricing

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Publisher :
ISBN 13 :
Total Pages : 1312 pages
Book Rating : 4.3/5 (91 download)

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Book Synopsis Transfer Pricing by : Mukesh Butani

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).

Practical Guide to U.S. Transfer Pricing

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Author :
Publisher : Aspen Publishers
ISBN 13 :
Total Pages : 1302 pages
Book Rating : 4.0/5 ( download)

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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.

Resolving Transfer Pricing Disputes

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Author :
Publisher : Cambridge University Press
ISBN 13 : 1139916289
Total Pages : 975 pages
Book Rating : 4.1/5 (399 download)

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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.

Bharat's Law & Practice of Transfer Pricing

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Publisher :
ISBN 13 : 9789351394921
Total Pages : 1111 pages
Book Rating : 4.3/5 (949 download)

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Book Synopsis Bharat's Law & Practice of Transfer Pricing by : Divakar Vijayasarathy

Download or read book Bharat's Law & Practice of Transfer Pricing written by Divakar Vijayasarathy and published by . This book was released on 2017 with total page 1111 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Transfer Pricing in India

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Publisher :
ISBN 13 : 9789389176247
Total Pages : 507 pages
Book Rating : 4.1/5 (762 download)

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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:

Fundamentals of Transfer Pricing

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Publisher : Kluwer Law International B.V.
ISBN 13 : 9403535202
Total Pages : 549 pages
Book Rating : 4.4/5 (35 download)

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Book Synopsis Fundamentals of Transfer Pricing by : Raffaele Petruzzi

Download or read book Fundamentals of Transfer Pricing written by Raffaele Petruzzi and published by Kluwer Law International B.V.. This book was released on 2022-06-20 with total page 549 pages. Available in PDF, EPUB and Kindle. Book excerpt: This is Part Two of a crucially significant two-volume set on the nature of transfer pricing that fully elucidates how the growing body of applicable rules works in practice. The preceding volume, subtitled General Topics and Specific Transactions, focused on basic principles and specialized topics. This volume enlarges the scope of the first volume, particularly concerning industry specifics, regional considerations, the use of new technologies, and the intersection between transfer pricing rules and other disciplines. As in the first volume, stakeholding contributors from government, multinational companies, international organizations, advisory groups, and academia offer deeply informed perspectives, both general and specific, on the practical application of transfer pricing rules. With numerous examples and relevant international judicial precedents, the authors augment the first volume in such ways as the following: extended analysis of particular business sectors, including automotive, banking, consumer goods, insurance, IT, oil and gas, and pharmaceutics; specific jurisdictional coverage of the United States, the European Union, Brazil, China, and India; detailed presentation of the use of new technologies by both taxpayers and tax authorities; and further in-depth analysis of transfer pricing’s interaction with various fields of law. With this authoritative source of practical guidance, advisors, in-house practitioners, government officials, and academics worldwide will have all the details they need to move forward in tackling the complex aspects of the current transfer pricing environment.

Fundamentals of Transfer Pricing

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Publisher :
ISBN 13 : 9789041189943
Total Pages : 0 pages
Book Rating : 4.1/5 (899 download)

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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.

Taxmann's BEPS Implications on Transfer Pricing | Indian Perspective – Comprehensive and Practical Guide with Analysis | Case Studies | Practical Strategies for Tax Professionals

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Publisher : Taxmann Publications Private Limited
ISBN 13 : 9357783504
Total Pages : 24 pages
Book Rating : 4.3/5 (577 download)

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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

Transfer Pricing and Regulations for India

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Author :
Publisher : UBS Publishers' Distributors
ISBN 13 : 9788174763952
Total Pages : 246 pages
Book Rating : 4.7/5 (639 download)

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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.

Taxmann's Law of Transfer Pricing in India

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Publisher :
ISBN 13 : 9788171946181
Total Pages : 904 pages
Book Rating : 4.9/5 (461 download)

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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.

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

Download 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 PDF Online Free

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Publisher : Taxmann Publications Private Limited
ISBN 13 : 939221183X
Total Pages : 43 pages
Book Rating : 4.3/5 (922 download)

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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….”

Law of Transfer Pricing in India

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Publisher :
ISBN 13 : 9789350715338
Total Pages : 1075 pages
Book Rating : 4.7/5 (153 download)

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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:

Transfer Pricing

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Publisher :
ISBN 13 : 9781617468421
Total Pages : pages
Book Rating : 4.4/5 (684 download)

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Book Synopsis Transfer Pricing by : Patrick Cheung (Accountant)

Download or read book Transfer Pricing written by Patrick Cheung (Accountant) and published by . This book was released on with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: "... presents the rules and practice related to transfer pricing in Hong Kong, India, Ireland, and Italy"--P. iii.

Transfer Pricing Audit Practices in India

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Publisher :
ISBN 13 : 9789351437093
Total Pages : 635 pages
Book Rating : 4.4/5 (37 download)

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Book Synopsis Transfer Pricing Audit Practices in India by : M. S. Vasan

Download or read book Transfer Pricing Audit Practices in India written by M. S. Vasan and published by . This book was released on 2016 with total page 635 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Transfer Pricing Theory & Practice

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Publisher :
ISBN 13 : 9789389859614
Total Pages : pages
Book Rating : 4.8/5 (596 download)

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Book Synopsis Transfer Pricing Theory & Practice by :

Download or read book Transfer Pricing Theory & Practice written by and published by . This book was released on 2020 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:

OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2017

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Author :
Publisher : OECD Publishing
ISBN 13 : 9264265120
Total Pages : 612 pages
Book Rating : 4.2/5 (642 download)

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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.