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Magnificent Transfer Pricing Pack – Transfer Pricing in India (1st Edition) | A Practical Approach to Arm’s Length Pricing | Transfer Pricing (Domestic & International Transactions) (6th Edition) | Decoding Transfer Pricing for Selling (Distribution and Agency) Functions

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  • The pack contains following titles 
    • A Practical Approach to Arm’s Length Pricing
    • Transfer Pricing (Domestic & International Transactions) (6th Edition)
    • Decoding Transfer Pricing for Selling (Distribution and Agency) Functions
    • Transfer Pricing in India (1st Edition)
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Transfer Pricing in India (1st Edition)

Categories: International Taxation, Transfer Pricing
Publisher: Taxsutra and Bharat Law House Pvt Ltd
About Book:Tax evasion and tax avoidance are the basic problems faced by the revenue authorities of most of the countries of the world. This problem has become more acute due to globalisation and digitisation of the economy. Transfer pricing is one of the main reasons. Though transfer pricing is relevant for all transactions, but it is more relevant to transactions between close relative and associated concerns. This is my fourth book on transfer pricing. There was a need for a smaller book on TP, which can cater to the needs of common tax practitioners. Therefore, I have written this book from the perspective of small and medium tax practitioners. In this book, both the provisions applicable to Domestic TP and International TP are discussed. This book is mainly based on Indian statutory provisions along with decided cases from Indian judiciary. However, I have relied also on OECD’s Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations and the United Nations Practical Manual on Transfer Pricing for Developing Countries. This book covers all aspects of transfer pricing (both domestic and international) along with practice manual.

This book is divided in nine parts as under: 

  • Part 1 – What is Transfer Pricing
  • Part 2 – Domestic TP – Specified Domestic Transactions
  • Part 3 – Scope of Transfer Pricing – International Transactions
  • Part 4 – Computational Provisions – Transfer Pricing Methods
  • Part 5 – Computational Provisions – Comparability Analysis
  • Part 6 – Types of International Transactions
  • Part 7 – Audit and Assessment
  • Part 8 – Dispute Resolution – Avoiding and Resolving Mechanism
  • Part 9 – Indian Statutory Provisions

Further, this book also contains guidance on the following topics:

  • TP Certificate (Form 3CEB)
  • TP Documentation (TP Study)
  • Guide to Assessment (before TPO and AO)
  • Objections before Dispute Resolution Panel

Author: Hari Om Jindal

About Author:

Hari Om Jindal :1. Sh. Hari Om Jindal qualified the Chartered Accountancy Course (ICAI) in the year 1989 and became FCA in 1994. He completed his Bachelor of Commerce (Honours) from Kurukshetra University, India in 1985. He has also done Certificate Course on International Taxation from Institute of Chartered Accountant of India in 2009.
2. He is practicing Chartered Accountant in India since 1989.
3. His practice area includes, domestic taxation, international taxation and transfer pricing.
4. He has written following books;

➢ Indian Transfer Pricing in relation to International Taxation, 2015 edition published by Young Global; [https://www.linkedin.com/pulse/transfer-pricing- relation-international-transactions-young-global-s][ https://www.amazon.in/Transfer-Pricing-Relation-International- Transactions/dp/8188274283]

➢ Law Relating to Transfer Pricing with OECD Transfer Pricing Guidelines, 2011
edition published by Taxmann; [https://www.taxmann.com/bookstore/

professional/law-relating-to-transfer-pricing-with-oecd-transfer-pricing- guidelines-2010.aspx]

➢ Business Expenditure Law and Practice with CD (Set of 2 Volumes), first edition in 2007 and second edition in 2008 published by Taxmann. [https://www.scribd. com/doc/116915222/Taxmann-Books]

5. He was managing editor of “Global Taxation” a journal on international taxation, transfer pricing & BEPS. [https://ke.linkedin.com/in/young-global-s-60063bba] 6. Earlier, he was also Coordinating Editor of “International Taxation”, a journal on international taxation, from 2009 to 2014.
7. He was also Coordinating Editor of Taxmann’s website on international taxation (https://ilt.taxmann.com/index.aspx) from 2011 to 2013.
8. He is also transfer pricing advisor to Mauritius Government (Mauritius Revenue Authority)
9. He has attended IFA World Congress held in Rome 2010 (Italy), Boston 2012 (USA), Mumbai 2014 (India), Madrid 2016 (Spain) and he was also Indian branch joint reporter on transfer pricing (one of the two scientific subjects) for IFA 2017 World Congress, held in Brazil.
10. He has written more than 100 articles on income tax, transfer pricing, international taxation and service tax,

About Publisher:About Taxsutra:

Taxsutra is considered the most credible source of tax news in the tax fraternity. What started as a fledgling start-up has now become a leading brand in the tax world not only in India, but across the globe. Taxsutra’s diverse customer set includes Fortune 500 Companies, large Indian Business Groups, Global Conglomerates, Tax Judges, IRS Officers, CBDT, Tax Lawyers & thousands of tax practitioners.

Taxsutra suite of portals : 

1. Real time tax news & analysis for Corporate Tax (www.taxsutra.com/dt)
2. Transfer Pricing Portal (www.taxsutra.com/tp)
3. GST and Central Indirect Taxes Portals (www.taxsutra.com/gst – www.idt.taxsutra.com)
4. “Taxsutra Database” – Powerful Online Direct Tax Reference and Search Tool (www.database.taxsutra.com)
5. LawStreetIndia (LSI) (www.lawstreetindia.com) contains sub-modules on Company law, Securities law (SEBI/SAT), FEMA, IP laws & Competition Law
6.  Taxsutra Accounting Standards portal (Ind-AS) (www.greentick.taxsutra.com)

About Bharat Law House Pvt Ltd

Bharat is a ‘trade-name’ for a group of concerns, popularly known as Bharat Law House and Bharat Law House Pvt. Ltd. Bharat is one of the most reputed publishers of law books with an experience of over six decades. It possess a very diverse range of publications covering not only the area of taxation – direct and indirect – but also company law, insolvency capital market, finance, industrial law, foreign exchange, commercial, civil and criminal laws. The students publications for CA, CS, CMA, CFA, MBA, graduate and post-graduate studies have carved out a niche for themselves. The Publication House has a professionally qualified team with strong in-house capabilities. Their strength lies in the patronage of legal luminaries in every field. They strive for accuracy, authenticity and sincerity.

A Practical Approach to Arm’s Length Pricing

Categories: Transfer Pricing
Publisher: Taxsutra and Thomson Reuters South Asia Private Limited
About Book:A Practical Approach to Arm’s Length Pricing provides a hands-on and technical guide to niche issues in transfer pricing. The first part of the book delves deep into the challenges faced in arm’s length pricing of transactions involving intangibles such as patents, know- how, copyrights, trademarks, exploitation rights and so on. It discusses the nuances of finding the arm’s length range of royalty rates, IP transfers, hard-to-value intangibles and marketing intangibles. The second part discusses new reforms in transfer pricing regimes around the world, fair transfer pricing policies in some typical industries, and issues such as comparability adjustments and benchmarking of corporate guarantee transactions.

There is a dearth of literature on the practical aspects of transfer pricing practice that A Practical Approach to Arm’s Length Pricing seeks to rectify. It discusses methods and models of benchmarking complex transactions, and goes on to demonstrate – step by step – how these methods and models can be used to arrive at the arm’s length standard. The nuances arising from assessment and litigation trends have also been highlighted.

Author: Smarak Swain

About Author:

Smarak Swain : Smarak Swain graduated in Electrical Engineering from Indian Institute of Technology, Kharagpur in 2006, and joined the Indian Revenue Service (IRS) in 2008. He has also done Masters in Taxation and Business Laws (MTBL) from NALSAR University, Hyderabad. He has also authored the critically acclaimed guide to BEPS, Tangible Guide to Intangibles: Identification, Valuation, Taxation and Transfer Pricing. Through his writings, he aims to bring about tax transparency in the way businesses operate and see a genuine increase in India’s tax paying behaviour. In the Income tax department, he has wide exposure in the fields of audit, assessment, investigation, transfer pricing, and international taxation. He is originally from Orissa and currently lives in Bangalore with his family. His articles have been published in The Mint, Economic Times, First Post, and Asia Times.
About Publisher:About Taxsutra:

Taxsutra is considered the most credible source of tax news in the tax fraternity. What started as a fledgling start-up has now become a leading brand in the tax world not only in India, but across the globe. Taxsutra’s diverse customer set includes Fortune 500 Companies, large Indian Business Groups, Global Conglomerates, Tax Judges, IRS Officers, CBDT, Tax Lawyers & thousands of tax practitioners.

Taxsutra suite of portals : 

1. Real time tax news & analysis for Corporate Tax (www.taxsutra.com/dt)
2. Transfer Pricing Portal (www.taxsutra.com/tp)
3. GST and Central Indirect Taxes Portals (www.taxsutra.com/gst – www.idt.taxsutra.com)
4. “Taxsutra Database” – Powerful Online Direct Tax Reference and Search Tool (www.database.taxsutra.com)
5. LawStreetIndia (LSI) (www.lawstreetindia.com) contains sub-modules on Company law, Securities law (SEBI/SAT), FEMA, IP laws & Competition Law
6.  Taxsutra Accounting Standards portal (Ind-AS) (www.greentick.taxsutra.com)

About Thomson Reuters South Asia Private Limited:

Thomson Reuters is one of the world’s most trusted providers of answers, helping professionals make confident decisions and run better businesses. Thomson Reuters, India, Legal is a part of this group and publishes legal content covering a spectrum of topics by leading experts and professionals in this domain. Newgen, a contracting affiliate of Thomson Reuters, India, Legal produces and promotes these publications on their behalf across South East Asia.

Transfer Pricing (Domestic & International Transactions) (6th Edition)

Categories: International Taxation, Transfer Pricing
Publisher: Bharat Law House Pvt Ltd
About Book:Highlights:

  1. Simple and exhaustive coverage of the legal provisions
  2. Transfer pricing laws as amended by Finance Act, 2022 have been covered
  3. Relevant case laws have been analysed and summarized to provide a ready reference for transfer pricing case laws
  4. Comparison of safe harbour margins with actual margins through benchmarking analysis
  5. The process of benchmarking with recognized databases have been explained by a simple step by step approach with screen shots depictions
  6. Completed Audit Report Format in Form 3CEB, Safe Harbour Form 3CEFA and Form 3CEFB, APA Forms 3CEC and 3CED
  7. Practical check list for fulfilling Accountant’s responsibility while certifying Form 3CEB
  8. Over 70 practical issues faced by the assessee/tax advisors during the course of compliance and assessments have been elaborately discussed
  9. Significant recent rulings have been briefly analyzed

Author: Divakar Vijayasarathy

About Author:

Divakar Vijayasarathy :Divakar Vijayasarathy, founder and managing partner of DVS Advisors, is a rank holder chartered accountant and an ex-banker, with strong passion towards domestic and international taxation law. Mr. Divakar is an alumni of Harvard Business School. An ex-banker and with significant exposures in both domestic and international markets, he founded the firm with a single-minded objective to provide value added cross border services to mid and large businesses having global aspirations.

A passionate orator and professor on the subject of international and domestic taxation laws, he has presented numerous seminars across various professional and institutional forums. He has authored more than 15 books most of which have been national publications and has been part of several study groups constituted by various Committees of the Institute of Chartered Accountants of India. A renowned expert on the subject of international tax, he is part of the expert team of ICAI for the certified course on International Taxation. He is a regular columnist and expert consultant for various national publications in India.

About Publisher:Bharat is a ‘trade-name’ for a group of concerns, popularly known as Bharat Law House and Bharat Law House Pvt. Ltd. Bharat is one of the most reputed publishers of law books with an experience of over six decades. It possess a very diverse range of publications covering not only the area of taxation – direct and indirect – but also company law, insolvency capital market, finance, industrial law, foreign exchange, commercial, civil and criminal laws. The students publications for CA, CS, CMA, CFA, MBA, graduate and post-graduate studies have carved out a niche for themselves. The Publication House has a professionally qualified team with strong in-house capabilities. Their strength lies in the patronage of legal luminaries in every field. They strive for accuracy, authenticity and sincerity.

Decoding Transfer Pricing for Selling (Distribution and Agency) Functions

Categories: Transfer Pricing
Publisher: Taxsutra and Thomson Reuters South Asia Private Limited
About Book:One of the most litigated areas around selling functions, both internationally and particularly in India, is whether a licensee of trademark contributes to unique and valuable marketing intangibles through the intensity of its selling functions; and if so, how should arm’s length rewards be assigned to it. Decoding Transfer Pricing for Selling (Distribution and Agency) Functions aims to carry out advanced statistical analysis of selected empirical data to ascertain whether a licensee of trademark may be said to contribute to unique marketing intangibles. The book also focuses on identifying sophisticated economic adjustments, if any, to arrive at feasible results for measuring the impact of such unique marketing intangibles under the conventional transfer pricing methods of ‘one sided’ testing or adopt the profit split method as a better recourse.

Author: Rahul K. Mitra

About Author:

Rahul K. Mitra :

  • Rahul Mitra is a freelance practicing Chartered Accountant, with over 27 years of experience in handling taxation matters in India. He specialises in transfer pricing, supply chain management projects, international taxation, BEPS, profit attribution to permanent establishments, etc.
  • Rahul was a tax partner with PwC and KPMG for an aggregate period of almost 20 years, including having served both the organisations as their national transfer pricing leader.
  • Rahul was the country reporter on the topic, “Non-Discrimination in international tax matters”, for the IFA Congress held in Brussels in 2008.
  • Rahul was invited by the OECD to speak in the 2012 Paris roundtable conference on developing countries’ perspective on APAs.
  • Rahul was invited by President of the Tax Tribunal in 2012 and the Indian Revenue Board in 2015 and 2019 to impart training on the topic of transfer pricing to Members of the Tax Tribunal and Senior Officials of the Indian Revenue respectively.
  • Rahul has been consistently rated as a leading transfer pricing professional and tax litigator in India by Euromoney and International Tax Review, since 2010.
  • Rahul received the “International Tax Contributing Author of the Year” award in the subject of transfer pricing in 2019 from Bloomberg Tax.
  • Rahul is a member of the global editorial board of the international web-based tax magazine, Bloomberg BNA Transfer Pricing Forum.
  • Rahul independently handles litigation for top companies at the level of Tax Tribunals; and has won several landmark rulings before Tax Tribunals in the field of transfer pricing, creating precedents in India, in matters relating to Berry Ratio, Marketing Intangibles; Selection of Tested Party; Corporate Guarantee; Profit Split Method; Supply Chain nuances etc.
  • Rahul has handled several APAs and MAPs in India, involving clients from across industries, covering complex transactions, e.g. industrial franchise fees under non-integrated principal structure; attribution of profits to dependent agency permanent establishment model; contract R&D service provider models; distribution models with related marketing intangible issues; financial transactions (loans and guarantees); profit split model for royalties; etc.
About Publisher:About Taxsutra:

Taxsutra is considered the most credible source of tax news in the tax fraternity. What started as a fledgling start-up has now become a leading brand in the tax world not only in India, but across the globe. Taxsutra’s diverse customer set includes Fortune 500 Companies, large Indian Business Groups, Global Conglomerates, Tax Judges, IRS Officers, CBDT, Tax Lawyers & thousands of tax practitioners.

Taxsutra suite of portals : 

1. Real time tax news & analysis for Corporate Tax (www.taxsutra.com/dt)
2. Transfer Pricing Portal (www.taxsutra.com/tp)
3. GST and Central Indirect Taxes Portals (www.taxsutra.com/gst – www.idt.taxsutra.com)
4. “Taxsutra Database” – Powerful Online Direct Tax Reference and Search Tool (www.database.taxsutra.com)
5. LawStreetIndia (LSI) (www.lawstreetindia.com) contains sub-modules on Company law, Securities law (SEBI/SAT), FEMA, IP laws & Competition Law
6.  Taxsutra Accounting Standards portal (Ind-AS) (www.greentick.taxsutra.com)

About Thomson Reuters South Asia Private Limited:

Thomson Reuters is one of the world’s most trusted providers of answers, helping professionals make confident decisions and run better businesses. Thomson Reuters, India, Legal is a part of this group and publishes legal content covering a spectrum of topics by leading experts and professionals in this domain. Newgen, a contracting affiliate of Thomson Reuters, India, Legal produces and promotes these publications on their behalf across South East Asia.

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