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Law Relating to Transfer Pricing with Transfer Pricing Audit
Author
Specifications
  • ISBN 13 : 9789387702578
  • year : 2018
  • language : English
  • binding : Softback
Description
Contents: Book one: General principles of transfer pricing. 1. Introduction. 2. Features of the transfer pricing regime under chapter x. 3. Transfer pricing provisions of chapter x - when applicable to an assessee. 4. Transfer pricing compliances. Book two: Division one. Applicability of TPR to International transactions. 5. Who are “associated enterprises” (AES)? 6. What is “international transaction”? 7. International transactions: purchase, sale or lease of tangible property. 8. International transactions: intangible property transactions. 9. International transactions: borrowing or lending of money/Financing. 10. International transactions: provision of services. 11. International transactions: cost Contribution agreements. 12. Business restructuring or organization. Division Two: Computation Of Arm’s Length Price Of International Transactions. 13. What is arm’s length price. 14. How to compute arm’s length price. Division Three: Comparability Analysis of International Transactions. 15. Benchmarking : comparability analysis and comparables. 16. Understanding business, industry and controlled transaction. 17. Examination of comparability factors of controlled transaction. 18. Tested party. 19. Identification of ‘comparables’. 20. Data to be used in comparability analysis. 21. What is comparable uncontrollable price (CUP) method and how to apply it to calculate ALP? 22. What is resale price method (RPM) and how to apply it to calculate ALP? 23. What is cost plus method (CPM) and how to apply it to calculate ALP? 24. What is profit split method (PSM) and how to apply it to calculate ALP? 25. What is transactional net margin method (TNMM) and how to apply it to calculate ALP? 26. Any other method - rule 10AB. 27. Most appropriate method (MAM). 28. International transactions : determination of alp for import of goods. 29. International transactions : determination of alp for interest free loan to AES. 30. International transactions involving intangibles: determination of alp. 31. International transactions : when development centres in India can be treated as contract R&D service provider with insignificant risk. 32. International transactions: determination of alp for indenting activity. Division Four: TP Adjustments, Thin Cap Adjustments and Secondary Adjustments In International Transactions. 33. Transfer pricing adjustments. 34. Thin capitalization adjustments. 35. Secondary adjustments. Division Five: Transfer Pricing Procedures. 36. Power of AO to compute alp. 37. Reference to transfer pricing officer - section 92CA. 38. Transfer pricing dispute resolution mechanism. 39. Safe harbour rules. 40. Advance pricing agreement. 41. Obligation of assessees to maintain transfer pricing documentation. 42. Audit report. 43. Audit report and documentation - international transactions. 44. Due date for filing return for assessees required to furnish audit report u/s 92e - section 139. 45. Time limits for assessment and reassessment - sections 153 and 153b. Book Three: Specified Domestic Transactions. 46. Definition of specified domestic transactions. 47. Audit report and documentation -specified domestic transactions. Book Four: Miscellaneous. 48. Penalty - sections 271, 271aa, 271ba and 271g. Appendices.