| |
Complete and Authentic Commentary on Law Relating to Transfer Pricing in INDIA, EU, USA, CANADA and NETHERLANDS with OECD Transfer Pricing Guidelines 2010
Transfer Pricing in India
· Transfer pricing provisions as applicable to domestic transactions together with estimation of profits when accounts of the taxpayers are disbelieved
· Concept of International Transaction and Associated Enterprise
· Determination of ALP and Transfer Pricing Methods
· What are Comparables and how the adjustments are made
· Concept of Most Appropriate Method and 5% Safe Harbour Rule
· Provisions relating to transfer pricing audit, assessment and reference to TPO
· Documentation requirement and Burden of Proof
· Penal consequences together with Dispute Avoidance and Resolution Mechanism
· Proposed Transfer Pricing regime under DTC 2010
Transfer Pricing in European Union
· OECD TP Guidelines treatment in the relevant EU country
· Priorities/pricing methods
· Transfer pricing penalties and penalty relief
· Documentation requirements and deadlines
· Return disclosures/related-party dis-closures
· APA opportunity
· Case law on transfer pricing under the relevant EU country
Transfer Pricing in United States
· Specified Transfer Pricing Methods applicable in case of Controlled Transfers of Tangible Property, Use of Intangible Property Services, Transactions Related Party Loans, Cost Sharing Arrangements and Global Dealing Operations
· Transfer Pricing Documentation and Penalties
· Transfer Pricing Audit Procedure, Burden of Proof and Transfer Pricing Dispute Resolution mechanism
· Concepts of APAs
· Transfer Pricing and Tax Treaties together with MAP procedure
Transfer Pricing in Canada
· Transfer Pricing Methods and concept of APAs
· Downward Transfer Pricing Adjustments
· Transfer Pricing Penalty Provisions and Documentation Requirements
Transfer Pricing in Netherlands
· Incorporation of Transfer Pricing in Dutch National Law
· Relationship to the OECD transfer pricing guidelines
· Consequences of applying incorrect transfer prices
· APA Ruling
· Burden of Proof & Transfer Pricing
ISBN No.:9788171949342
|
| |
|