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Decoding Transfer Pricing for Selling Functions

Decoding Transfer Pricing for Selling Functions

by Rahul K. Mitra
Marketing Intangibles Transfer Pricing Berry Ratio
About Book:

Key Features:

  • Are some of the theories of OECD and UN around marketing intangibles sacrosanct ?
  • The same have been countered through qualitative and quantitative arguements.
  • Quantitative arguements are based upon real life scenarios, with reference to statistical analyses on selected empirical data.
  • Genesis of litigation around marketing intangibles analysed, along with solutions.
  • Concept of royalties for licensed manufacturers explained in the context of regulatory regime of India.
  • Practical solutions provided on harmonisation of transfer pricing and customs duty regulations in complex cases.
  • Concept of attribution of profits to dependent agency permanent establishments explained, with reference to Berry Ratio.
  • Foreword by Dr. Raffalle Dr. Raffaele Petruzzi & Dr. Alfred Storck Professors of Vienna University of Economics and Business 
Categories: Transfer Pricing
Publisher: Wolters Kluwer
About Publisher:

Wolters Kluwer Tax & Accounting in India (www.cchifirm.co.in), provides publishing, software and services that deliver vital insights, intelligent tools and guidance of subject-matter experts as well as offer subscription-based products with high quality content in areas including direct and indirect taxation, international taxation, corporate law and several other related topics. Wolters Kluwer Tax & Accounting (a Wolters Kluwer business) is part of the Wolters Kluwer Group, a leading global information service provider for professionals. Wolters Kluwer Tax & Accounting publications cover a wide range of topics such as tax, accounting, law, financial planning, human resources and training.

Author: Rahul K. Mitra
About Author:
Rahul K. Mitra :
  • Rahul Mitra is a freelance practicing Chartered Accountant, with over 27 years of experience in handling taxation matters in India. He specialises in transfer pricing, supply chain management projects, international taxation, BEPS, profit attribution to permanent establishments, etc.
  • Rahul was a tax partner with PwC and KPMG for an aggregate period of almost 20 years, including having served both the organisations as their national transfer pricing leader.
  • Rahul was the country reporter on the topic, “Non-Discrimination in international tax matters”, for the IFA Congress held in Brussels in 2008.
  • Rahul was invited by the OECD to speak in the 2012 Paris roundtable conference on developing countries’ perspective on APAs.
  • Rahul was invited by President of the Tax Tribunal in 2012 and the Indian Revenue Board in 2015 and 2019 to impart training on the topic of transfer pricing to Members of the Tax Tribunal and Senior Officials of the Indian Revenue respectively.
  • Rahul has been consistently rated as a leading transfer pricing professional and tax litigator in India by Euromoney and International Tax Review, since 2010.
  • Rahul received the “International Tax Contributing Author of the Year” award in the subject of transfer pricing in 2019 from Bloomberg Tax.
  • Rahul is a member of the global editorial board of the international web-based tax magazine, Bloomberg BNA Transfer Pricing Forum.
  • Rahul independently handles litigation for top companies at the level of Tax Tribunals; and has won several landmark rulings before Tax Tribunals in the field of transfer pricing, creating precedents in India, in matters relating to Berry Ratio, Marketing Intangibles; Selection of Tested Party; Corporate Guarantee; Profit Split Method; Supply Chain nuances etc.
  • Rahul has handled several APAs and MAPs in India, involving clients from across industries, covering complex transactions, e.g. industrial franchise fees under non-integrated principal structure; attribution of profits to dependent agency permanent establishment model; contract R&D service provider models; distribution models with related marketing intangible issues; financial transactions (loans and guarantees); profit split model for royalties; etc.

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Overall Rating
Review
Marketing Intangibles Transfer Pricing Berry Ratio
About Book:

Key Features:

  • Are some of the theories of OECD and UN around marketing intangibles sacrosanct ?
  • The same have been countered through qualitative and quantitative arguements.
  • Quantitative arguements are based upon real life scenarios, with reference to statistical analyses on selected empirical data.
  • Genesis of litigation around marketing intangibles analysed, along with solutions.
  • Concept of royalties for licensed manufacturers explained in the context of regulatory regime of India.
  • Practical solutions provided on harmonisation of transfer pricing and customs duty regulations in complex cases.
  • Concept of attribution of profits to dependent agency permanent establishments explained, with reference to Berry Ratio.
  • Foreword by Dr. Raffalle Dr. Raffaele Petruzzi & Dr. Alfred Storck Professors of Vienna University of Economics and Business 
Categories: Transfer Pricing
Publisher: Wolters Kluwer
About Publisher:

Wolters Kluwer Tax & Accounting in India (www.cchifirm.co.in), provides publishing, software and services that deliver vital insights, intelligent tools and guidance of subject-matter experts as well as offer subscription-based products with high quality content in areas including direct and indirect taxation, international taxation, corporate law and several other related topics. Wolters Kluwer Tax & Accounting (a Wolters Kluwer business) is part of the Wolters Kluwer Group, a leading global information service provider for professionals. Wolters Kluwer Tax & Accounting publications cover a wide range of topics such as tax, accounting, law, financial planning, human resources and training.

Author: Rahul K. Mitra
About Author:
Rahul K. Mitra :
  • Rahul Mitra is a freelance practicing Chartered Accountant, with over 27 years of experience in handling taxation matters in India. He specialises in transfer pricing, supply chain management projects, international taxation, BEPS, profit attribution to permanent establishments, etc.
  • Rahul was a tax partner with PwC and KPMG for an aggregate period of almost 20 years, including having served both the organisations as their national transfer pricing leader.
  • Rahul was the country reporter on the topic, “Non-Discrimination in international tax matters”, for the IFA Congress held in Brussels in 2008.
  • Rahul was invited by the OECD to speak in the 2012 Paris roundtable conference on developing countries’ perspective on APAs.
  • Rahul was invited by President of the Tax Tribunal in 2012 and the Indian Revenue Board in 2015 and 2019 to impart training on the topic of transfer pricing to Members of the Tax Tribunal and Senior Officials of the Indian Revenue respectively.
  • Rahul has been consistently rated as a leading transfer pricing professional and tax litigator in India by Euromoney and International Tax Review, since 2010.
  • Rahul received the “International Tax Contributing Author of the Year” award in the subject of transfer pricing in 2019 from Bloomberg Tax.
  • Rahul is a member of the global editorial board of the international web-based tax magazine, Bloomberg BNA Transfer Pricing Forum.
  • Rahul independently handles litigation for top companies at the level of Tax Tribunals; and has won several landmark rulings before Tax Tribunals in the field of transfer pricing, creating precedents in India, in matters relating to Berry Ratio, Marketing Intangibles; Selection of Tested Party; Corporate Guarantee; Profit Split Method; Supply Chain nuances etc.
  • Rahul has handled several APAs and MAPs in India, involving clients from across industries, covering complex transactions, e.g. industrial franchise fees under non-integrated principal structure; attribution of profits to dependent agency permanent establishment model; contract R&D service provider models; distribution models with related marketing intangible issues; financial transactions (loans and guarantees); profit split model for royalties; etc.

Similar Books

Ratings and Reviews

Overall Rating
Review
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