International Business and Transfer Pricing: Concepts and Jurisprudence

Commercial?s International Business and Transfer Pricing: Concepts and Jurisprudence is a profound work that blends legal principles, economic theories, and judicial precedents to trace the evolution of global commerce and transfer pricing frameworks.

Structured in six insightful chapters, the book spans the journey of international trade?from ancient exploration-driven exchanges to the modern complexities of digital multinational enterprises. It examines intra-group structures, the Arm?s Length Principle with DEMPE (Development, Enhancement, Maintenance, Protection, and Exploitation) analysis, and global frameworks ranging from the 1928 Revenue Act through BEPS initiatives, alongside comparisons with India?s domestic regime.

Drawing on the lifetime scholarship of Shri S.C. Mishra, a distinguished former member of the Indian Revenue Service, the book reflects his hallmark insistence on clarity, structured reasoning, and analytical precision. Edited by Shri S.P. Singh, the volume balances conceptual depth with practical application, ensuring readers can connect statutory provisions with real-world business challenges.

Key Highlights
? Comprehensive Coverage: Six chapters covering the evolution of international trade, MNE structures, transfer pricing principles, and comparative global frameworks.
? Arm?s Length Principle & DEMPE: Detailed discussion on application in modern transfer pricing practice.
? Historical to Contemporary: From the 1928 Revenue Act to OECD BEPS initiatives and India?s evolving TP regime.
? Judicial Jurisprudence: Integration of landmark precedents shaping global and Indian approaches.
? Student-Friendly: As noted by the editor, a ?goldmine for students? offering clarity and structured reasoning.

Utility

This book is an essential resource for tax professionals, policymakers, academicians, students, and practitioners of international business law. It offers both a conceptual framework and practical insights, making it a reliable guide to navigating the complexities of transfer pricing and global tax jurisprudence.