Bharat Transfer Pricing (Domestic and International Transactions) By Divakar Vijayasarathy Edition September 2022

Bharat Law & Practice of Transfer Pricing By Divakar Vijayasarathy

Bharat Law & Practice of Transfer Pricing By Divakar Vijayasarathy

Content

Chapter 1 Relevance and Rationale of Transfer Pricing
Chapter 2 Transfer Pricing Law in India
Chapter 3 Methods for Determining the Arm’s Length Price
Chapter 4 Functions, Assets and Risk (Far) Analysis
Chapter 5 Benchmarking and Selection of Comparables
Chapter 6 Domestic Transfer Pricing
Chapter 7 Transfer Pricing for Loss-Making Companies
Chapter 8 Transfer Pricing for Specialised Capital Goods
Chapter 9 Transfer Pricing Documentation
Chapter 10 Master File and Country-by-Country Reporting in India
Chapter 11 Advance Pricing Agreements — An Indian Perspective
Chapter 12 Mutual Agreement Procedure
Chapter 13 Safe Harbour Guidelines With Comparison
Chapter 14 Action Points on Transfer Pricing and Action Plan 13 — Transfer Pricing Documentation and Country-by-Country Reporting
Chapter 15 Form 3CEB and Auditor’sResponsibility
Chapter 16 Interplay of GAAR and Transfer Pricing
Chapter 17 Interplay of Dtaa and Transfer Pricing
Chapter 18 Practical issues in Transfer Pricing
Chapter 19 Transfer Pricing Adjustment
Chapter 20 Recent Decisions on Transfer Pricing Law
Chapter 21 Range Concept and Multi-Year Data
Chapter 22 Limitation on Interest Deductions and Transfer Pricing for Financial Transactions
Chapter 23 Statistics on Transfer Pricing
Chapter 24 Transfer Pricing — Global Perspective
Chapter 25 UN Practical Manual on Transfer Pricing
Chapter 26 Impact of Covid-19 on Transfer Pricing
Chapter 27 Judicial Precedents
Chapter 28 Sample Transfer Pricing Report — Case Study 1
Chapter 29 Sample Transfer Pricing Report — Case Study 2
Chapter 30 Statutory Provisions, Circulars and Notifications
Chapter 31 Glossary

About the Author

Shri Divakar Vijayasarathy?is a rank holder chartered accountant engaged in international and domestic taxation practice. His core areas of practice are international tax structuring, transfer pricing, tax advisory and tax litigation. He ventured into practice after successful employment stints with leading banks and financial institutions. He is a faculty for the subjects of direct and international taxation for both students and professionals at ICAI and various other professional institutions.