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Transfer Pricing Fundamentals


Description of the Course:

Transfer pricing is one of the most important tax issues faced in the international arena of enterprises and tax administrations. In the global era of corporatization and Multi-National Corporations, Transfer Pricing has emerged as a field of interest for various professionals.


What will you learn in this Transfer Pricing Course?

At the end of the Transfer Pricing course by CAclubindia, you will have thorough understanding of all the fundamental concepts of Transfer Pricing and various methods of computation of ArmÔ?Ts Length Price.
You will also learn about Safe Harbor Provisions in Transfer Pricing and APA (Advanced Pricing Agreement) under the Indian Transfer Pricing Regulations.


Who should enroll this course?

This Transfer Pricing course is for everyone (including professionals) who wishes to learn and study Transfer Pricing and wants to make a promising career in Transfer Pricing or International Tax Domain.


This Transfer Pricing course is for:

This course has been designed in the Indian context covering all the transfer pricing provisions and regulations of the Indian legislation.

  • CAs in Practice who wish to diversify their practice in the International Tax field

  • CAs in Job who wish to get promoted and achieve greater goals

  • CA Students and Fresher CAs who wish to learn the basic and advanced concepts of Transfer Pricing


Content of the Course:


Concept of Transfer Pricing

  • Introduction to Transfer Pricing

  • Notified Jurisdiction Area - Concept and Implications

  • Examples on Transfer Price

  • Examples on Common Transactions between Non Residents

  • Law on Transfer Pricing - Pre and Post 2001

  • Introduction of Transfer Pricing Law

  • Cost Allocation or Apportionment between Associated Enterprises

  • Section 92 - Arm's Length Price

  • Base Erosion Concept

  • Example on Base Erosion Concept

  • Associated Enterprises - Meaning and Definition

  • Concept of Deemed Enterprise in Transfer Pricing

  • Deemed Associated Enterprises - Clause i to iii

  • Deemed Associated Enterprises - Clause iv to vi

  • Deemed Associated Enterprises - Case vi

  • Deemed Associated Enterprises - Clause vii to ix

  • Deemed Associated Enterprises - Clause x

  • Deemed Associated Enterprises - Remaining clauses

  • Examples on Associated Enterprises

  • International Transaction - Meaning

  • Example on International Transaction

  • International Transaction - Part 2

  • Deemed International Transaction

  • More Examples on International Transaction

  • Introduction to Arm's length Principle

  • Arm's length Price - Definition

  • Methods under Arm's length Price

  • Introduction to Comparable Uncontrolled Price Method

  • Steps in Comparable Uncontrolled Price - Part 2

  • Examples on Comparable Uncontrolled Price - 1-4

  • Examples on Comparable Uncontrolled Price - Number 5

  • Resale Price Method with Examples

  • Cost Plus and Profit Split method

  • TNMM


Range Concept and Documentation under Transfer Pricing

  • Range Concept - Part 2

  • Range Manner of Assigning Weight

  • FAR analysis and its components - Part 1

  • FAR analysis and its components - Part 2

  • Transfer Pricing documentation

  • Documentation and related penalties


Specified Domestic Transactions under Transfer Pricing

  • Introduction

  • Applicability of International transaction provisions


Transfer Pricing Assessment

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

  • Secondary Adjustment in transfer pricing

  • Time limit for completion of assessment

  • Dispute Resolution in transfer pricing


Safe Harbor

  • Safe Harbor for International transactions

  • Safe Harbor Provisions

  • Domestic Safe Harbor Rules - Introduction

  • Domestic Safe Harbor Rules - Part 2


Advance Pricing Agreements (APA)

  • What is APA and type of APA

  • Consequences of declaring APA as void

  • Process of APA and Terms of APA

  • Furnishing of return, revision and cancellation

  • Roll back provisions


Transfer Pricing - Miscellaneous Provisions

  • Example on Notified Jurisdiction Area

  • Section 93

 


Faculty Profile:



CA Arinjay Kumar Jain


B. Com., FCA Director


M&A Tax at KPMG Delhi (2006 to 2014) -
Worked on International tax with over 750 transaction of Inbound Investment, Outbound Investments, Due diligence, Family Structuring and Succession planning across sectors.


Editor International Tax at Taxmann Publications, New Delhi -
Handled the Journal on International Tax with Taxmann Publications, India's oldest Publishing house on tax and corporate law publications.

Faculty at the International tax Course of ICAI during the year 2009 & 2010


Trained over 1500 CA's in International tax till date at Corporates and Consulting Firms.

Created India's first e learning course on International tax for professionals in 2016 with students from over 30 countries.

Erstwhile Faculty for Interns at one of the Big Fours for CA Final aspirants.

Created a repository of
over 2000 videos for Students under a Not for profit initiative
with over 30,000 subscribers on YouTube



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