Demystifying TP through Judicial Precedents

Course Duration:
165 minutes comprising of 2 episodes

Course Background:
Transfer pricing (TP) professionals have seen a great deal of change in 2020. The COVID-19 crisis has made old problems worse, and created some new ones, for taxpayers. Meanwhile, the OECD is still trying to settle the technical aspects of its blueprints for digital tax reform. 

Particularly w.r.t transfer pricing (TP), it continues to be a major source of controversy for taxpayers. Historic cases like Apple and Glencore have reached outcomes this year, and the precedents set by these cases will have implications for many years to come.

What shall the course cover?
Against this backdrop, Taxsutra is delighted to present to you a special module on “Demystifying Transfer Pricing through Important Judicial Precedents” by Dr. (C.A) Sunil Moti Lala , Advocate & Tax Counsel.

Dr. Lala has been recognised in the Tax Controversy Leaders Guide by World Tax in association with International Tax Review for the last 7 consecutive years. In this module, Dr. Lala shall discuss and analyze several Indian case laws, based on the following themes vis-à-vis TP :

1.      Applicability of TP

2.      International Transaction & Deemed International Transaction

3.      Associated Enterprise

4.      Foreign AE as a Tested Party

5.      Method for determining ALP-CUP / RPM

6.      Comparability – Inter & Intra Industry

7.      Specific Transactions – AMP; Share Transaction & Quasi Capital; Interest on Outstanding Receivables; Loans; Royalty & Technical Fee Payment

8.      Assessment

9.     Section 10A / Section 10B deduction on TP Adjustment