Transfer Pricing Law and Practice in India including BEPS
About the book
Globalisation has become a strategic practice for many business organisations in respect of services, manufacturing activities, the recent growth in off-shored business services and development of intangibles. This has brought transfer pricing to the fore-front of international taxation for all stake holders in economic activities – policy makers, business persons and tax consultants. An important development in the recent time has been concerned and expressed by the policy makers in respect of Base Erosion and Profit Shifting (BEPS). The Actions suggested by the international organisations are making paradigm shift in the concepts of international taxation, including transfer pricing. All stake holders must, not only be aware of the developments but take necessary suitable actions. 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 and BEPS seeks to provide these in one place.
The book embodies an exhaustive commentary on the law as well as recent updates in transfer pricing arena till date. The contents have been grouped under various chapters to enable a thorough insight to the reader and to make complex issues easy to comprehend. An attempt has been made to bridge the gap between theoretical concepts and practical applications of transfer pricing in India.
The updated Fifth edition of the book serves within its ambit the salient and topical aspects emanating from the plethora of legaljudgements delivered by various Appellate Authorities spread across the country.
- Updated up to the Finance Act, 2017
- An insight about Three-tiered transfer pricing documentation regime in India as well as globally
- Salient features of BEPS recommendations regarding transfer pricing along with conceptual understanding of Action 8, 9 and 10 from Indian standpoint
- Developing perspective about multilateral instruments recommended under Action 15 and its acceptance globally
- Covers more than 170 case laws exclusively in a separate chapter
- Pictorial presentation and description on issues interlinked with the concepts of International Taxation and Transfer Pricing.
- Typical transactions in relation to loans/ guarantees/ business restructuring/ intangibles have been covered in separate chapters
- Discerning provisions on secondary adjustment, revision in safe harbour rules among others.
- Discussion on the dispute resolution including the introduction of APA / MAP regime in India along with sharing of experiences across industries.
- Understanding amended provisions of domestic transfer pricing
- Implications of Ind AS adoption on transfer pricing
- Key highlights on the concept of risk based assessment
- Useful tools have been drawn in the form of Appendices
- Detailed discussion on BEPS Action Plan 8, 9 10 & 13 relevant to Transfer Pricing in a separate booklet.
About the Author
Deloitte globally provides audit, tax, consulting, and financial advisory services to public and private clients spanning multiple industries. With a globally connected network of member firms in more than 150 countries, Deloitte brings world-class capabilities and high-quality service to clients, delivering the insights they need to address their most complex business challenges. Deloitte has in the region of 210,000 professionals, all committed to becoming the standard of excellence.
In India, Deloitte member firms are spread across 13 locations with around 30,000 professionals who take pride in their ability to deliver to clients the right combination of local insight and international expertise.