Transfer Pricing (Domestic & International Transactions) (7th Edition, 2025)
- Year of Publication: 2025
- Edition: 7th
- ISBN: 978-81-19565-74-0
- No.of Pages: 1225
Transfer Pricing, as an area of practice, has assumed enormous significance given the inherent ambiguous nature of the law and the scope for wide interpretations. The recent decisions by courts and the actions of the Revenue are an indicator of the direction in which this levy is poised. This book aims to simplify the provisions of international and domestic transfer pricing law in India. The book is viewed as an assessee and practitioner guide to transfer pricing to facilitate the interpretation and compliance of the legislation. Some of the highlighting features of this book are:—
- Simple and exhaustive coverage of the legal provisions
- Transfer pricing laws as amended by the Finance Act, 2025 have beencovered
- UN Manual and OECD Guidelines have been referenced throughout for holistic understanding of the concepts.
- Existing TP-legislation has been compared with provisions of the proposed Income Tax Bill, 2025 to provide a glimpse of evolution of TP- legislation.
- Twosample transfer pricing study reports have been provided to provide a practical dimension to documentation
- Relevant case laws have been analysed and summarized to provide a ready reference for transfer pricing case laws
- Comparison of safe harbour margins with actual margins through benchmarking analysis
- The process of benchmarking with recognised databases have been explained by a simple step by step approach with screen shots depictions
- Completed Audit Report Format in Form 3CEB, Safe Harbour Form 3CEFA and Form 3CEFB, APA Forms 3CEC and 3CED
- Practical check list for fulfilling Accountant responsibility while certifyingForm 3CEB
- Over 70 Practical issues faced by the assessee/tax advisors during the course of compliance and assessments have been elaborately discussed
- Supreme Court rulings have been extensively analysed
Divakar Vijayasarathy, founder and managing partner of DVS Advisors, is a rank holder chartered accountant and an ex-banker, with strong passion towards domestic and international taxation law. Mr. Divakar is an alumni of Harvard Business School. An ex-banker and with significant exposures in both domestic and international markets, he founded the firm with a single-minded objective to provide value added cross border services to mid and large businesses having global aspirations.
A passionate orator and professor on the subject of international and domestic taxation laws, he has presented numerous seminars across various professional and institutional forums. He has authored more than 15 books most of which have been national publications and has been part of several study groups constituted by various Committees of the Institute of Chartered Accountants of India. A renowned expert on the subject of international tax, he is part of the expert team of ICAI for the certified course on International Taxation. He is a regular columnist and expert consultant for various national publications in India.
Sundara Rajan leads the International Tax and Transactions practice at DVS. He is a Chartered Accountant with more than a decade of experience in International Tax, FEMA and Mergers. He is an active researcher in the space and regularly contributes to leading media houses on the subject. Sundar works closely with leading corporations in FMCG, Automobile, Textile, IT industry, etc and has been consistently recognised by his clients for his clarity of thought and ability to break down complex problems. Prior to this stint, Sundar was into credit underwriting and has underwritten over Rs. 5000 crores of SME retail book across Southern India for leading NBFCs.
Bharat is a 'trade-name' for a group of concerns, popularly known as Bharat Law House and Bharat Law House Pvt. Ltd. Bharat is one of the most reputed publishers of law books with an experience of over six decades. It possess a very diverse range of publications covering not only the area of taxation - direct and indirect - but also company law, insolvency capital market, finance, industrial law, foreign exchange, commercial, civil and criminal laws. The students publications for CA, CS, CMA, CFA, MBA, graduate and post-graduate studies have carved out a niche for themselves. The Publication House has a professionally qualified team with strong in-house capabilities. Their strength lies in the patronage of legal luminaries in every field. They strive for accuracy, authenticity and sincerity.
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- Year of Publication: 2025
- Edition: 7th
- ISBN: 978-81-19565-74-0
- No.of Pages: 1225
Transfer Pricing, as an area of practice, has assumed enormous significance given the inherent ambiguous nature of the law and the scope for wide interpretations. The recent decisions by courts and the actions of the Revenue are an indicator of the direction in which this levy is poised. This book aims to simplify the provisions of international and domestic transfer pricing law in India. The book is viewed as an assessee and practitioner guide to transfer pricing to facilitate the interpretation and compliance of the legislation. Some of the highlighting features of this book are:—
- Simple and exhaustive coverage of the legal provisions
- Transfer pricing laws as amended by the Finance Act, 2025 have beencovered
- UN Manual and OECD Guidelines have been referenced throughout for holistic understanding of the concepts.
- Existing TP-legislation has been compared with provisions of the proposed Income Tax Bill, 2025 to provide a glimpse of evolution of TP- legislation.
- Twosample transfer pricing study reports have been provided to provide a practical dimension to documentation
- Relevant case laws have been analysed and summarized to provide a ready reference for transfer pricing case laws
- Comparison of safe harbour margins with actual margins through benchmarking analysis
- The process of benchmarking with recognised databases have been explained by a simple step by step approach with screen shots depictions
- Completed Audit Report Format in Form 3CEB, Safe Harbour Form 3CEFA and Form 3CEFB, APA Forms 3CEC and 3CED
- Practical check list for fulfilling Accountant responsibility while certifyingForm 3CEB
- Over 70 Practical issues faced by the assessee/tax advisors during the course of compliance and assessments have been elaborately discussed
- Supreme Court rulings have been extensively analysed
Divakar Vijayasarathy, founder and managing partner of DVS Advisors, is a rank holder chartered accountant and an ex-banker, with strong passion towards domestic and international taxation law. Mr. Divakar is an alumni of Harvard Business School. An ex-banker and with significant exposures in both domestic and international markets, he founded the firm with a single-minded objective to provide value added cross border services to mid and large businesses having global aspirations.
A passionate orator and professor on the subject of international and domestic taxation laws, he has presented numerous seminars across various professional and institutional forums. He has authored more than 15 books most of which have been national publications and has been part of several study groups constituted by various Committees of the Institute of Chartered Accountants of India. A renowned expert on the subject of international tax, he is part of the expert team of ICAI for the certified course on International Taxation. He is a regular columnist and expert consultant for various national publications in India.
Sundara Rajan leads the International Tax and Transactions practice at DVS. He is a Chartered Accountant with more than a decade of experience in International Tax, FEMA and Mergers. He is an active researcher in the space and regularly contributes to leading media houses on the subject. Sundar works closely with leading corporations in FMCG, Automobile, Textile, IT industry, etc and has been consistently recognised by his clients for his clarity of thought and ability to break down complex problems. Prior to this stint, Sundar was into credit underwriting and has underwritten over Rs. 5000 crores of SME retail book across Southern India for leading NBFCs.
Bharat is a 'trade-name' for a group of concerns, popularly known as Bharat Law House and Bharat Law House Pvt. Ltd. Bharat is one of the most reputed publishers of law books with an experience of over six decades. It possess a very diverse range of publications covering not only the area of taxation - direct and indirect - but also company law, insolvency capital market, finance, industrial law, foreign exchange, commercial, civil and criminal laws. The students publications for CA, CS, CMA, CFA, MBA, graduate and post-graduate studies have carved out a niche for themselves. The Publication House has a professionally qualified team with strong in-house capabilities. Their strength lies in the patronage of legal luminaries in every field. They strive for accuracy, authenticity and sincerity.
