Transfer Pricing (Domestic & International Transactions)

Transfer Pricing (Domestic & International Transactions) by Divakar Vijayasarathy and Sundara Rajan TK is a comprehensive guide that delves into the intricacies of transfer pricing laws in India, as amended by the Finance Act, 2025. This 7th edition offers an exhaustive analysis of both domestic and international transfer pricing regulations, making it an indispensable resource for tax professionals, chartered accountants, and legal practitioners.

Key Features:

• The book provides a detailed examination of the legal provisions governing transfer pricing, ensuring readers have a thorough understanding of the subject.
• Relevant case laws are analyzed and summarized, offering a ready reference for transfer pricing case laws and aiding in practical application.
• The authors compare safe harbour margins with actual margins through benchmarking analysis, providing insights into the practical aspects of transfer pricing.
• The process of benchmarking with recognized databases is explained through a simple, step-by-step approach, complete with screenshot depictions for clarity.
• Includes completed audit report formats in Form 3CEB, Safe Harbour Form 3CEFA and 3CEFB, APA Forms 3CEC and 3CED, and a practical checklist for fulfilling an accountant’s responsibility while certifying Form 3CEB.
• Over 70 practical issues faced by assessees and tax advisors during compliance and assessments are elaborately discussed, providing real-world context.
• Significant recent rulings are briefly analyzed, keeping readers updated on the latest developments in transfer pricing law.

This book is an essential resource for professionals seeking to navigate the complexities of transfer pricing laws and ensure compliance with the latest regulations.

Chapter 1 Relevance and Rationale of Transfer Pricing
Chapter 2 Transfer Pricing Law in India
Chapter 3 Methods for Determining the Arm's Length Price
Chapter 4 Functions, Assets and Risk (FAR) Analysis
Chapter 5 Benchmarking and Selection of Comparables
Chapter 6 Transfer Pricing Adjustment
Chapter 7 Range Concept and Multi-year Data
Chapter 8 Transfer Pricing for Loss-Making Companies
Chapter 9 Transfer Pricing for Specialised Capital Goods
Chapter 10 Transfer Pricing for Startups
Chapter 11 Limitation on Interest Deductions and Transfer Pricing for Financial Transactions
Chapter 12 Domestic Transfer Pricing
Chapter 13 Safe Harbour Guidelines With Comparison
Chapter 14 Practical Issues in Transfer Pricing
Chapter 15 Transfer Pricing Documentation
Chapter 16 Form 3CEB and Auditor's Responsibility
Chapter 17 Master File and Country-by-Country Reporting in India
Chapter 18 Advance Pricing Agreements — An Indian Perspective
Chapter 19 Mutual Agreement Procedure
Chapter 20 Interplay of GAAR and Transfer Pricing
Chapter 21 Interplay of DTAA and Transfer Pricing
Chapter 22 Transfer Pricing — Global Perspective
Chapter 23 Transfer Pricing in UAE
Chapter 24 Supreme Court Decisions on Transfer Pricing Law
Chapter 25 UN & OECD Practical Manual on Transfer Pricing
Chapter 26 Sample Transfer Pricing Report — Case Study 1
Chapter 27 Sample Transfer Pricing Report — Case Study 2
Chapter 28 Statutory Provisions, Circulars and Notifications
Chapter 29 Glossary