Fundamentals of Transfer Pricing

Description

In this Course, Basics of Transfer Pricing, the students would be able to learn about various concepts of Transfer Pricing, Methods of Transfer Pricing and their applicability, Advance pricing agreements and Safe Harbor Provisions. This course is meant for audience in India, who want to gain basic knowledge of Transfer Pricing. The language used is both English and Hindi and anyone who is not well versed with Hindi should not subscribe to the course . The course takes into consideration, the Indian Transfer Pricing regulations, as the basis of course content. The other topics covered include

What is Transfer pricing - Meaning of Transfer Pricing and Objectives of Transfer Pricing

• Transfer Pricing Concept under International Taxation

• Transfer Pricing - Example to understand the Concept

• Examples on Common Transactions between Non residents which are covered under Transfer Pricing

• Transfer Pricing Law - Prior to 2001 and after 2001

• Introduction of Transfer Pricing Law

• Cost Allocation or apportionment between Associated Enterprises

  
  

  Arm Length Price and Associated Enterprises under Transfer Pricing Course

  • Section 92 of Indian Income Tax Act, 1961 - Arm's Length Price

  • Base Erosion Concept

  • Example on Base Erosion Concept

  • Associated Enterprises - Meaning and definition

  
  

  Deemed Associated Enterprise Concept

  • Concept of Deemed Enterprise Transfer Pricing

  • Deemed Associated Enterprises - Case i to iii

  • Deemed Associated Enterprises - Case iv to vi

  • Deemed Associated Enterprises - Case vi

  • Deemed Associated Enterprises - Clause vii to ix

  • Deemed Associated Enterprises - Clause x

  • Deemed Associated Enterprises - Section 92A(2) - Remaining clauses

  
  

  International Transaction - What are International Transaction under Transfer Pricing ?

  • Examples on Associated Enterprise

  • International Transaction - Meaning

  • Example on International Transaction - Transfer Pricing

  • International Transaction Part 2

  • Deemed International Transaction

  • More Examples on International Transaction

    
    

    ALP and CUP Method - Transfer Pricing

  • Arm's Length Principle Meaning

  • Arm's Length Price Meaning - Section 92F of Income Tax Act 1961

  • Computation of Arm's Length Price

  • Introduction to Comparable Uncontrolled Price Method

  • Steps in Comparable Uncontrolled Price Method

  • Examples on Comparable Uncontrolled Price - Part 1

  • Examples on Comparable Uncontrolled Price - Part 2

  
  

  Resale Price method, Cost Plus Method and Transactional Net Margin Method

  • Resale Price Method with Examples

  • Cost Plus Method and Profit Split Method

  • Transactional Net Margin Method in Transfer pricing - (TNMM)

  • Other Method, MAM determination, Tested Party etc

  
  

  Range and TP documentation - Transfer Pricing

  • Transfer Pricing Range Concept - Single and Multiple Year data (Part1)

  • Range Concept (Part 2)

  • Range Manner of Assigning Weight

  • Functions, Asset and Risk Analysis - FAR analysis and its components (Part 1)

  • Functions, Asset and Risk Analysis - FAR analysis and its components (Part 2) and Documentation

  • Transfer Pricing Documentation

  • Country By Country Reporting - CBC Reporting

  
  

  Specified Domestic Transaction (SDT)

  • Specified Domestic Transaction

  • Applicability of International transaction provisions

  • Remaining provisions of Specified Domestic Transaction

  
  

  Transfer Pricing Assessment in India

  • Power of AO to ascertain ALP and reference to the TPO

  • Secondary Adjustment in Transfer Pricing

  • Time limit for completion of Assessment

  • Dispute Resolutions in Transfer pricing

  
  

  Safe Harbor Rules

  • Safe Harbour Provisions for International Transactions

  • Safe Harbour Provisions

  • Example on Safe Harbour and AO jurisdiction under TP to be broken into two parts

  • Domestic Safe Harbor Rules Introduction

  • Domestic Safe Harbor Rules (Part 2)

  
  

  Advance Pricing Agreement (APA) - Ability to arrive at Arm's Length price

  • What is an APA, Type of APA - Unilateral and Bilateral, Requirement, Advantages of APA

  • Consequences of Declaration of an APA as void AB Initio - Section 92CC

  • Process of APA and terms of APA - Transfer Pricing

  • Furnishing of Return, Revision and Cancellation of an APA

  • Roll back provisions in Advance Pricing Agreement

  • Roll back provisions in Advance Pricing Agreement (Part 2)

  
  

  Mutual Agreement Procedure (MAP) - Transfer Pricing

  • Mutual Agreement Procedure

  
  

  Transfer Pricing Miscellaneous

  • Notified Jurisdiction Area - Section 94A

  • Example on Notified Jurisdiction Area

  • Section 94B and Section 93

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