Recent Trends in Transfer Pricing Intangibles, GAAR and BEPS by
he growing importance of the intangible assets in the global economy coupled with expanding international intra-firm trade, has meant that transfer pricing issues concerning intangibles have assumed critical importance for both the Multi National Enterprises as well as Tax authorities. The identification, accounting and valuation of intangibles is a challenging and evolving field. This volume details the various such issues and concerns from both industry and revenue perspective. Further, the contemporary issues of digital economy, tax planning, BEPS, GAAR have also been extensively dealt with.
Key features:
• Explains in detail the meaning of various types of intangibles as defined in Income Tax Act.
• Discusses the various possible methodologies for valuing the intangibles including the typical and residual methods
• Accounts for all the relevant changes suggested by the OECD in the BEPS Action Point 8-10 report regarding intangibles
• Valuation of Highly Uncertain as well Hard-to-Value Intangibles
• Relevant Features of and taxation challenges posed by Digital economy
• Various possible techniques of Tax Planning adopted by the Multi-national Enterprises
• All the BEPS Action Point Reports along with recommendations as adopted globally as well as in India including Thin Capitalisation, Poem, Equalisation Levy, amended DTAAs with Mauritius, Cyprus and Singapore {Updated up to Finance Bill, 2017 (India)}
• Transfer Pricing Aspects of CCAs, Intra-group Services and Business Restructuring including issue of indirect transfers
• Discussion on General Anti Avoidance Rules, to be implemented in India from 01/04/2017
• Famous and important global and Indian case laws with regard to intangibles
• Detailed discussion on issue of AMP expenses and marketing intangibles
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About the Author
Dr. Ravi Kant Gupta is an officer of 2005 batch of Indian Revenue Service (IRS) cadre, Government of India. He is a medical graduate (MBBS, Punjab University) and did his postgraduate in management (PGDM) majoring in Finance and Strategy, from Indian Institute of Management (IIM) Lucknow. During the course of service he has completed Bachelors in Law (LLB, Mumbai University) and Masters in Taxation and Business Laws (MTBL) from NALSAR University of Law. Having been selected for prestigious Chevening Scholarship, he is currently pursuing Masters in Public Administration and Management (MPA) from acclaimed University College London, UK. In his career spanning 11 years as an IRS officer hitherto, he has worked in various capacities as an Assistant Commissioner Income Tax in the non-corporate and corporate assessment charges at Mumbai. He also served as the Deputy Director Income Tax (Investigation), Mumbai, India; where he was involved in many key and sensitive investigations. For almost three years he served as Director, National Health Mission, Haryana undertaking many initiatives for improving the health indicators of mothers and infants in the state. He served as the Joint Commissioner Income Tax (Transfer Pricing) at Pune, India; where he audited several cases of MNEs involving complex transfer pricing issues. He has always been involved in academics besides pursuing his career. For his MTBL in 20010, he wrote his thesis on “Recent Trends in Transfer Pricing”. For his valuable contribution to “Let us Share”, Dr Gupta has been awarded Appreciation Certificate by CBDT in 2011 and 2012. He is a highly distinguished officer of his IRS batch, having been awarded, V R Bapat Memorial Gold Medal for academics, V R Akerkar Gold Medal for Income Tax and C C Ganapathy Memorial Gold Medal for accounting at National Academy of Direct Taxes, Nagpur. Dr Gupta is an avid traveller, photographer, fitness enthusiast and can speak Hindi, English, Punjabi and French.