Transfer Pricing Audit Practices in India  attempts to disentangle the complex web of transfer pricing controversies. This book is based on Indian Transfer Pricing audit experiences for the period ranging from 2003-04 till date, right from TPO to appellate authorities, thereby proving guidance to 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. he Slient feature of the Book includes:

• * 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 defendin their transfer pricing litigation.
• * Provide solutions for risk mitigation and Controversy resolution

1. Introduction
2. Administrative Set-up Appellate Authorities and Alternate Dispute Resolution Mechanisms.
3. Transfer Pricing Methodology - Application and Issues
4. Transfer Pricing Analysis
5. Selection of Comparables
6. Special Transactions
7. Transfer Pricing Audit Practices
8. Attribution of Profits to Permanent Establishment
9. Domestic Transfer Pricing
10. Tranfer Pricing Audit Preparation and Guidance Note
11. Transfer Pricing Risk Management
12. Base Erosion and Profit Shifting (BEPS) - A New Look at Transfer Pricing
13. Important Case Law and Key Learnings
14. Conclusion : The Reality of Transfer Pricing

Appendices :

1. Transfer Pricing - Suggested Answers
2. Analysis of Case Law
3. Relevant Circulars, Notifications and Press Release
4. Form No. 3CEB
5. Form No. 3CEFA
6. Examples of Marketing Intangibles and Tax Office