Topics Covered under CA Final International Taxation Elective Paper 6C, Module 1 – Transfer Pricing
- Need of Transfer Pricing
- Applicability of TP in India
- Meaning of Transfer Price
- What is Transfer Price
- Evolution of TP in India [Pre 2001 ERA] – Section 92
- Computation of Income having regard to the ALP – Section 92
- Associated Enterprises TP – Section 92A (1)
- Deemed Associated Enterprises – Section 92A (2)
- International Transaction – Section 92B of Income Tax Act
- Arm’s Length Price
- Comparable Uncontrolled Price Method
- Resale Price Method
- Cost Plus Method
- Profit Split Method
- Transactional Net Margin Method (TNMM)
- Other method TP
- Functions Assets and Risks Analysis
- Documents and Compliances – Documentation required under the income tax act 1961
- Functional Analysis, Economic Analysis, Audit Report Section 92E
- Penalties – Section 270A, Section 271(AA)
- Country by Country Reporting
- Specified Domestic Transaction under TP
- Safe Harbour Rules for Specified Domestic Transaction
- Safe Harbour Rules for International Transaction
- TP Assessment Procedure in India
- Secondary Adjustment Section 92CE of Income Tax Act
- Dispute Resolution Mechanism under TP
- Advance Pricing Agreement
- Mutual Agreement Procedure
- Miscellaneous TP Provisions