The second edition of Transfer Pricing Audit Practices in India attempts to disentangle the complex web of transfer pricing controversies. Indian tax administration with its fifteen years of transfer pricing audit adjustments has realized that the pro-revenue positions will not stand the test of law. This book is based on Indian transfer pricing audit experiences for the period ranging from 23-4 till date, right from TPO to appellate authorities, thereby proving guidance to the tax authorities, taxpayers and tax professionals on technical issues and compliance. Domestic transfer pricing rules and audit approaches shall be helpful for taxpayers. BEPS has been elaborately discussed based on the final report. An insight into the tax audit process and risk based assessment has been dealt with in detail. The author has drawn from his practical experience of dealing with transfer pricing auditors to provide the taxpayer’s perspective on how to mitigate transfer pricing risk and reduce transfer pricing controversy. The book also highlights the gap in the positions and approach of the tax authorities and taxpayers, and is a good starting point to explore some form of alignment of these positions to ease the pain of taxpayers and potential investors. Salient Features • Clarify the technical aspects of transfer pricing • Present practical, on-the-ground facts during transfer pricing audits • Explain some of the relevant court rulings on transfer pricing that taxpayers are able to use in defending their transfer pricing litigation • Provide solutions for risk mitigation and controversy resolution
"Dr M S Vasan is the Executive Partner in M/s Lakshmikumaran & Sridharan, Attorneys. He is a practicing Advocate based in Delhi. He has over 25 years of work experience handling various tax matters — corporate taxation, transfer pricing and international taxation in the fields of textile, engineering, chemicals, life sciences, pharma, renewable energy, ITes and automobile appearing before various tax authorities and appellate forums in India and abroad. He is a Doctorate in Transfer Pricing. He holds Bachelor's Degree in Law, Master's degree in Commerce as well as Business Administration. He is an Associate Member of the Institute of Cost Accountants of India. He has been a regular contributor to various tax journals and publications on transfer pricing, international tax and other tax matters. He has been associated with various trade and industry forums that represent on tax policy recommendations. He has also authored Direct Taxes Ready Reckoner, 2014 edition and 2015 edition and Master Guide to Income Tax, 2015 edition published by LexisNexis. "