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Description
Written by Mukesh Butani, FCA, Transfer Pricing: An Indian Perspective, is a definitive reference guide to Indian legislation, overview of regulations in key jurisdictions and challenges associated with the administration of law. The revised edition focuses upon international developments and dispute resolution mechanism emerging as the most effective way to resolve disputes.
The first edition of the book, released in 2003, received an overwhelming response. Building upon the first edition, the revised edition seeks to provide up-to-date information and practical guidance on a wide range of transfer pricing issues including a detailed analysis of Indian legislation; a critical account of Indian audit experiences and controversies; comparison of Indian regulations with the OECD guidelines; tax planning techniques related to transfer pricing supplemented with case studies based on business models of transnational corporations; transfer pricing implications under tax treaties; recent Indian and international transfer pricing case laws, trends and surveys; updated discussion on transfer pricing regimes in key jurisdictions including United States, the United Kingdom, Australia, Canada, France, Germany, Japan, China and Singapore; full text of transfer pricing guidelines issued by OECD.
The treatise is an important reference guide for finance directors, group and international tax managers, business supply chain managers, Revenue officials, controllers and international tax practitioners.
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Contents
Chapter 1. An Introduction to Transfer Pricing
Chapter 2. Pre-2001 Scenario
Chapter 3. Introduction to the Indian Transfer Pricing Legislation
Chapter 4. Transfer Pricing Methods
Chapter 5. Transfer Pricing Rules - Documentation Requirements
Chapter 6. Transfer Pricing Controversies
Chapter 7. OECD - Background, Guidelines and Role in India
Chapter 8. Interplay of Double Taxation Avoidance Agreements
Chapter 9. Establishing a Transfer Pricing Policy - Practical Considerations
Chapter 10. The Role of Transfer Pricing in Tax Planning
Chapter 11. Recent International Developments, Court Cases, Trends and Surveys
Chapter 12. Transfer Pricing in Australia
Chapter 13. Transfer Pricing in Canada
Chapter 14. Transfer Pricing in China
Chapter 15. Transfer Pricing in France
Chapter 16. Transfer Pricing in Germany
Chapter 17. Transfer Pricing in Japan
Chapter 18. Transfer Pricing in Singapore
Chapter 19. Transfer Pricing in the United Kingdom
Chapter 20. Transfer Pricing in the United States
Chapter 21. Other Countries - Brief Overviews
Argentina
Austria
Belgium
Brazil
Czech Republic
Finland
Italy
Korea
Malaysia
Mexico
The Netherlands
New Zealand
Norway
Poland
South Africa
Spain
Sweden
Switzerland
Appendices
Appendix 1 - Indian Transfer Pricing Legislation
Appendix 2 - Comparable Search – Techniques and Concepts
Appendix 3 - Database Developments and Guide
Appendix 4 - International Case Laws
Appendix 5 - Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrators (OECD)
Appendix 6 - An Overview of the Draft Issue Notes on Comparability
Appendix 7 - Definition of Income Under Income Tax Act, 1961
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Author Details
Mukesh Butani is a fellow member of the Institute of Chartered Accountants of India. Mukesh was a tax practice leader with big four accounting firms and possesses competencies in international tax and transfer pricing matters. Mukesh has been part of the tax profession for over two decades and has worked extensively on a range of corporate tax, business reorganization and inbound/outbound structuring engagements for several Fortune 500 companies and Indian business houses. He specializes in advisory services in relation to interpretation of tax treaties and use of complex financing instruments. He has been actively engaged in tax dispute resolution through the administrative channels and mutual agreement procedure under tax treaties.
Surveys by International Tax Review have consistently rated Mukesh as amongst the leading individual tax advisors. World Tax 2006 and 2007 guide to world's leading tax firms have rated him as a leading tax advisor in the category of M&A and cross border structuring.
Mukesh features in legal media group's expert guide amongst the world's leading tax advisors and transfer pricing experts. Mukesh is a member of Taxation Commission of International Chamber of Commerce and actively associated with the task force on resolution of tax disputes through arbitration. Mukesh is a member of Organization of Economic Cooperation and Development's (OECD's) Business Restructuring Advisory Group.
He has served as a member of Government of India appointed task force on taxation of E-commerce and is the national reporter on the scientific topic of 'transfer pricing and intangibles' for 2007 Kyoto Congress of International Fiscal Association.
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