International Business And Transfer Pricing (2025 Edition)
- Year of Publication: 2025
- Edition: 2025
- ISBN: 978-93-49957-71-8
- No.of Pages: 542
International Business and Transfer Pricing written by Shri S.C. Mishra and edited by Shri S. P. Singh, represents a profound integration of legal principles, economic theories, and judicial precedents spanning global commerce evolution. Structured across six chapters, the book examines international trade from ancient explorations to digital MNEs, intra-group structures, the Arm's Length Principle with DEMPE analysis, global frameworks from 1928 Revenue Act through BEPS, and India's regime comparisons.
Authored by a distinguished scholar whose "insistence on clarity, structured reasoning, and analytical precision" marked his tenure in the Indian Revenue Service at various senior positions as policy maker and as administrator, this volume reflects lifetime scholarship and professional excellence.
This book combines conceptual depth with practical relevance—connecting statutory provisions with business realities while maintaining characteristic brevity. As the editor has noted, it is "a goldmine for students."
This volume is a tribute to Shri Mishra’s intellectual legacy that makes it an essential reading for tax professionals, policymakers, and students.
S.C. Mishra was former Director-General of Income-tax and author of Transfer Pricing Manual and Transfer Pricing in India: From Inception to BEPS. His areas of specialisation include tax policy, capacity building and training. He had wide experience in legislative drafting and amendment of direct tax laws. He participated in programmes on training methods, tax treaties and comparative tax laws in India and overseas. He 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 cases of tax frauds including cross-border transactions. However, the role that he cherished the most was as a training administrator where his job included identification of training needs, designing course profiles and evaluation of these programmes.
He was deeply interested in English literature and literature of Indian languages.
He loved going for long walks and listening to Hindustani classical music,
He breathed his last on 14th August 2024, while working on this book.
SP Singh (SP) is presently Senior Advisor to the Institute of Chartered Accountants of India JICAI). He started his career in 1976 as a lecturer of Physics in St. Xavier's College Ranchi. In 1979 he joined the Indian Revenue Service where he served for over two decades in various capacities. While in the Foreign Tax and Tax Research Division he was part of the team for negotiating and finalising several tax treaties. He was a member of the Expert Group on Transfer Pricing constituted by the Ministry of Finance for drafting the transfer pricing regulations.
Later, SP joined Deloitte India as Senior Director where he led several initiatives. SP has been recognized amongst World Leading Transfer Pricing Advisers as well as one of the global leaders in tax litigation for several years by international organisations.
SP has an MSc in Fiscal Studies from Bath University, UK, and earned a Master's in Physics in India. He has co-authored several books and regularly writes for taxation journals. His passion is wildlife and nature photography and running where he has participated in several half-marathon races
About Taxsutra
Taxsutra is considered the most credible source of tax news in the tax fraternity. What started as a fledgling start-up has now become a leading brand in the tax world not only in India, but across the globe. Taxsutra's diverse customer set includes Fortune 500 Companies, large Indian Business Groups, Global Conglomerates, Tax Judges, IRS Officers, CBDT, Tax Lawyers & thousands of tax practitioners.
Taxsutra suite of portals :
1. Real time tax news & analysis for Corporate Tax (www.taxsutra.com/dt)
2. Transfer Pricing Portal (www.taxsutra.com/tp)
3. GST and Central Indirect Taxes Portals (www.taxsutra.com/gst - www.idt.taxsutra.com)
4. "Taxsutra Database" - Powerful Online Direct Tax Reference and Search Tool (www.database.taxsutra.com)
5. LawStreetIndia (LSI) (www.lawstreetindia.com) contains sub-modules on Company law, Securities law (SEBI/SAT), FEMA, IP laws & Competition Law
6. Taxsutra Accounting Standards portal (Ind-AS) (www.greentick.taxsutra.com)
About Commercial Law Publishers (India) Pvt. Ltd.
Commercial LAW PUBLISHERS (INDIA) PVT. LTD. which is in the legal publishing business for nearly three decades is now one of the top ranking legal publishers in India–recognized and accepted by diverse professionals and business entities as well as Government Departments in view of the high quality, practical utility as well as diversity in subjects on which it brings out Books. It has the powerful backing of its vast exposure as the leading Books Distributor All over India for over 45 years. From just a couple of titles during the first few years of its publishing activity, Commercial has now around 200 titles and over 350 Bare Acts & Manuals in the field of Direct Indirect Taxes, Corporate Law and Civil/Criminal Laws. It successfully launched the Bare Acts project in the year 1996 and has so far brought out over 350 updated Bare Acts. These are much sought after since these Bare Acts are annotated ones containing notes and brief comments, thus enhancing their utility. Commercial has been bold enough to bring out Books, Commentaries and Referencers on hitherto untouched subjects like Legal Metrology. It has a record number of publications on Income Tax, Company Law, Customs, GST and Students Publications for CA & CS by bringing out high quality publications at affordable prices and is an highly ethical business enterprise. Commercial has withstood the market competition successfully over the years including competition from Foreign publishers and strives its best to serve the legal and corporate professionals better and better every day with its novel ideas and business strategy. Commercial is backed by a team of highly competent in-house professional experts supplemented by high profile authors who have stood by it for decades.
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- Year of Publication: 2025
- Edition: 2025
- ISBN: 978-93-49957-71-8
- No.of Pages: 542
International Business and Transfer Pricing written by Shri S.C. Mishra and edited by Shri S. P. Singh, represents a profound integration of legal principles, economic theories, and judicial precedents spanning global commerce evolution. Structured across six chapters, the book examines international trade from ancient explorations to digital MNEs, intra-group structures, the Arm's Length Principle with DEMPE analysis, global frameworks from 1928 Revenue Act through BEPS, and India's regime comparisons.
Authored by a distinguished scholar whose "insistence on clarity, structured reasoning, and analytical precision" marked his tenure in the Indian Revenue Service at various senior positions as policy maker and as administrator, this volume reflects lifetime scholarship and professional excellence.
This book combines conceptual depth with practical relevance—connecting statutory provisions with business realities while maintaining characteristic brevity. As the editor has noted, it is "a goldmine for students."
This volume is a tribute to Shri Mishra’s intellectual legacy that makes it an essential reading for tax professionals, policymakers, and students.
S.C. Mishra was former Director-General of Income-tax and author of Transfer Pricing Manual and Transfer Pricing in India: From Inception to BEPS. His areas of specialisation include tax policy, capacity building and training. He had wide experience in legislative drafting and amendment of direct tax laws. He participated in programmes on training methods, tax treaties and comparative tax laws in India and overseas. He 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 cases of tax frauds including cross-border transactions. However, the role that he cherished the most was as a training administrator where his job included identification of training needs, designing course profiles and evaluation of these programmes.
He was deeply interested in English literature and literature of Indian languages.
He loved going for long walks and listening to Hindustani classical music,
He breathed his last on 14th August 2024, while working on this book.
SP Singh (SP) is presently Senior Advisor to the Institute of Chartered Accountants of India JICAI). He started his career in 1976 as a lecturer of Physics in St. Xavier's College Ranchi. In 1979 he joined the Indian Revenue Service where he served for over two decades in various capacities. While in the Foreign Tax and Tax Research Division he was part of the team for negotiating and finalising several tax treaties. He was a member of the Expert Group on Transfer Pricing constituted by the Ministry of Finance for drafting the transfer pricing regulations.
Later, SP joined Deloitte India as Senior Director where he led several initiatives. SP has been recognized amongst World Leading Transfer Pricing Advisers as well as one of the global leaders in tax litigation for several years by international organisations.
SP has an MSc in Fiscal Studies from Bath University, UK, and earned a Master's in Physics in India. He has co-authored several books and regularly writes for taxation journals. His passion is wildlife and nature photography and running where he has participated in several half-marathon races
About Taxsutra
Taxsutra is considered the most credible source of tax news in the tax fraternity. What started as a fledgling start-up has now become a leading brand in the tax world not only in India, but across the globe. Taxsutra's diverse customer set includes Fortune 500 Companies, large Indian Business Groups, Global Conglomerates, Tax Judges, IRS Officers, CBDT, Tax Lawyers & thousands of tax practitioners.
Taxsutra suite of portals :
1. Real time tax news & analysis for Corporate Tax (www.taxsutra.com/dt)
2. Transfer Pricing Portal (www.taxsutra.com/tp)
3. GST and Central Indirect Taxes Portals (www.taxsutra.com/gst - www.idt.taxsutra.com)
4. "Taxsutra Database" - Powerful Online Direct Tax Reference and Search Tool (www.database.taxsutra.com)
5. LawStreetIndia (LSI) (www.lawstreetindia.com) contains sub-modules on Company law, Securities law (SEBI/SAT), FEMA, IP laws & Competition Law
6. Taxsutra Accounting Standards portal (Ind-AS) (www.greentick.taxsutra.com)
About Commercial Law Publishers (India) Pvt. Ltd.
Commercial LAW PUBLISHERS (INDIA) PVT. LTD. which is in the legal publishing business for nearly three decades is now one of the top ranking legal publishers in India–recognized and accepted by diverse professionals and business entities as well as Government Departments in view of the high quality, practical utility as well as diversity in subjects on which it brings out Books. It has the powerful backing of its vast exposure as the leading Books Distributor All over India for over 45 years. From just a couple of titles during the first few years of its publishing activity, Commercial has now around 200 titles and over 350 Bare Acts & Manuals in the field of Direct Indirect Taxes, Corporate Law and Civil/Criminal Laws. It successfully launched the Bare Acts project in the year 1996 and has so far brought out over 350 updated Bare Acts. These are much sought after since these Bare Acts are annotated ones containing notes and brief comments, thus enhancing their utility. Commercial has been bold enough to bring out Books, Commentaries and Referencers on hitherto untouched subjects like Legal Metrology. It has a record number of publications on Income Tax, Company Law, Customs, GST and Students Publications for CA & CS by bringing out high quality publications at affordable prices and is an highly ethical business enterprise. Commercial has withstood the market competition successfully over the years including competition from Foreign publishers and strives its best to serve the legal and corporate professionals better and better every day with its novel ideas and business strategy. Commercial is backed by a team of highly competent in-house professional experts supplemented by high profile authors who have stood by it for decades.
