Transfer Pricing - Demystified (Domestic & International Transactions)

The book gives definitions of various terms used in these regulations. It is very interesting to note that transfer pricing regulations bring new terms, hitherto unknown or referred to in tax journals in India. A separate list of all the abbreviations used in the context of transfer pricing regulations is given at the end as a Glossary.

The law of transfer pricing in India seeks guidance from well-known international principles, but these international principles also need debate on some of the fundamentals. In essence, the regulation in India has chosen its own path. Therefore, for a student of transfer pricing law in India, it is necessary to understand the statutory terms and the statutory format of the regulations in India which may differ from what the OECD or the United Nations' practical manual may have to say on a particular subject. This Book, therefore, explains the subject not only as per Indian regulations, but also exposes the reader to the OECD’s point of view/explanation. The Institute of Chartered Accountants of India’s publications have also been used to explain the various provisions and their implementation. Mathematical examples have been given wherever possible to explain the regulations, especially in the various methods and their application, their comparability and the adjustments required in the comparables to determine the arms’ length price. Separate chapters have also been added for maintenance and keeping of documents, certification, assessments, appeals and penalties. The

last chapter is with respect to controversies. This is in addition to the issues, such as, adjustments which are discussed in the chapter on adjustments. The controversies which are dealt with separately are self-illustrative in nature. The attempt is to convey the nature of controversy in an objective manner and to present the different views thereon.

The intention of this publication is that students of transfer pricing law as well as tax professionals, executives, business people and those in the tax administration, dealing with the transfer pricing regulations, will find the contents useful in making well informed briefs, documents and decisions.