Taxmanns BEPS Implications on Transfer Pricing | Indian Perspective Comprehensive and Practical Guide with Analysis | Case S

Updated Title Description This Book Offers A Comprehensive And Practical Guide To Understanding The Intricate Transfer Pricing Implications Stemming From The Base Erosion And Profit Shifting (Beps) Project Within The Indian Context. This Work Culminates Two Years Of Extensive Research And Analysis By A Team Of Transfer Pricing Experts. The Book Covers A Wide Range Of Topics, Starting With An Overview Of The Beps Project And Its Objectives. It Also Includes An Analysis Of International Rulings On Beps, Examining Landmark Cases And Their Implications For The Transfer Pricing Landscape.This Comprehensive Guide Is Invaluable For Tax Practitioners, Professionals, Academics, And Business Leaders Aiming To Understand The Impact Of Beps Recommendations On Transfer Pricing In India. It Facilitates Informed Discussions On This Critical Area Of Taxation And Its Implications For Businesses Operating In India.The Present Publication Is The Latest Edition, Authored By Ashutosh Mohan Rastogi, With The Following Noteworthy Features: [Realignment Of Transfer Pricing Norms] The Book Explains Why Beps Realigned Transfer Pricing Norms, Illustrated Through Case Studies Of Google, Starbucks, And Apple, Highlighting Their Implications On Beps [Understanding And Application Of Beps Action Plans] Beps Action Plans Have Transformed How Transfer Pricing Concepts Are Understood And Applied, Shifting Focus From Titles And Contracts To Functions And Risks. This Book Helps Readers Understand These Nuances In The PostBeps Era [Beps Insights On Indian Law] Each Chapter Provides Beps Insights On Indian Law, Discussing Beps Action Plans With Reference To Indian Regulations, Circulars, And Case Law And Explaining The Relevance And Implications Of Beps Action Points In The Indian Context [Planning For Intangibles In The PostBeps World] The Book Decodes How To Attribute Profits To Intangibles In The Beps Era, Explains Development, Enhancement, Maintenance, Protection And Exploitation (Dempe) Functions, And Assesses The Relevance Of Holding Companies In LowTax Havens Today [Economic Ownership] Readers Will Learn About The Importance Of Economic Ownership And How It Is Determined, Exploring How Indian Law Attributes Intangible Returns Based On Legal Or Economic Ownership [Substance In Transfer Pricing] The Book Discusses The Role Of Substance In Transfer Pricing, Exploring Whether Transfer Pricing Officers Can Look Beyond Agreements To Uncover Reality And The Role Of Significant People Functions [Benchmarking For Financial Transactions] It Provides Insights On Benchmarking For Financial Transactions Such As InterCompany Loans And Guarantees, Highlighting The Importance Of Credit Rating In Financial Transaction Analysis And How To Compute A Credit Rating [Location Savings] The Book Explains Where Location Savings Should Be Taxed And Whether Profit Split Is The Correct Methodology For Taxing Location Savings [Defending Management Charges] It Guides Multinational Enterprises (Mnes) On Defending Management Charges, The Availability Of Safe Harbour For Management Charges In India, And The Shortcomings Of The Safe Harbour [Cost Contribution Agreements] Readers Will Understand What Cost Contribution Agreements Are And How They Differ From IntraGroup Service Agreements [International Rulings On Beps] The Book Summarizes Leading International Rulings On Beps With Illustrations, Helping Readers Understand Their Implications And How Tax Litigators Can Apply Them In The Indian Context [ThreeTier Documentation With Faqs] From The Evolution And Objectives Behind The ThreeTier Approach To The Requirements Suggested By The Oecd And Their Adoption Into Indian Legislation, The Book Covers It All. It Includes Various Prescribed Templates And Answers To General And Transaction/IssueSpecific Faqs Addressed By The Oecd In The Beps Action Plan 13 Reportthe Detailed Contents Of The Book Are As Follows: [Introduction]O This Chapter Provides An Overview Of The Beps Project And Its Objectives, Including Case Studies Of Companies Like Starbucks, Google, And Apple, Illustrating The Necessity For The Beps Initiative [Beps Implications On Transfer Pricing]O This Chapter Provides An InDepth Examination Of Beps Implications On Transfer Pricing, Focusing On Fundamental Changes Proposed By The Oecd And Their Potential Impact On Mnes In India. It Analyses Concepts Such As Economic Substance, Substance Over Form, And Profit Shifting To LowTax Jurisdictions [Dempe Analysis]O This Chapter Provides A Detailed Discussion Of The Dempe (Development, Enhancement, Maintenance, Protection, And Exploitation) Functions, Highlighting The Complexities Of Attributing Profits To Intangible Assets And The Indian Tax Authorities Approach To These Challenges [Beps Guidance On Substance Over Form]O This Chapter Discusses The Principle Of Prioritizing Economic Substance Over Contractual Form, Emphasizing The Importance Of Actual Business Activities And Behaviours In Determining