The cross-border transaction flows are increasingly being scrutinized mainly because in the present times of fiscal constraints, the tax administrations attempt to secure a wider revenue base. The dynamics of changing business structures and regulatory regimes make the analysis of transfer pricing more challenging for the taxpayers and the tax authorities. In India, there is a growing corpus of case laws on transfer pricing.
This book covers the discussion on journey of Transfer Pricing from history to Future. The emergence of the provisions of Transfer Pricing, their evolvement to the current stage with the amendments in the law and the future outlook with BEPS are comprehensively discussed, with an outline on it’s implication on the stakeholders.
The author has made an endeavor to provide vast commentary on transfer pricing regulations with reference to the judicial pronouncements, not only of India but also which are decided in other geographies like United States, Canada etc. It has been written to make the task of the stakeholders a little easier in complying with the transfer pricing regulations. It covers the discussion on theoretical framework of international business and intra group relations followed by the objects of enquiry into such relations. The implication of BEPS has also been elucidated. It also covers the relevant portions of the OECD and US regulations. The provisions relating to documentation, penalty, risk assessment, audit and Dispute Resolution Mechanism has also been discussed.
About the Author
S C Mishra is former Director- General of Income-tax and author of Transfer Pricing Manual. His areas of specialisation include tax policy, capacity building and training. He has wide experience in legislative drafting and amendment of direct tax laws. He has participated in programmes on training methods, tax treaties and comparative tax laws in India and overseas. He has also conducted training programmes on taxation of non-residents. He was involved in designing training programmes for officers of developing countries. As a tax administrator, he investigated into cases of tax frauds comprising also of cross- border transactions. However, the role that he cherishes the most was as a training administrator where his job included identification of training needs, designing course profiles and evaluation of these programmes.