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
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
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 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
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