
This is a brief introduction to my course.
Here you get a short CV of your instructor. You can also get full details about my education and professional experience at my linkedIn profile at :
https://www.linkedin.com/in/pradipkumarghosh/
The learning outcome of the course is being briefly discussed here.
This is a realistic but simple example of transfer pricing issues. This shows how profit can be shifted out of India by over-invoicing.
Here I am describing the basic legislative framework of transfer pricing in India.
Here I am discussing the basic concepts through various sections of the Income Tax Act, 1961
Here are examples of various transfer pricing transactions,which can become suspects that arm's length pricing has not been followed.
Here I am discussing the concept of Arm's length price.
Here we are explaining the concept of associated enterprises.
Here,we are discussing one of the most used methods for determining arm's length price. This method is known as comparable uncontrolled price method or CUP.
Here we are discussing the Cost Plus method for determination of arm's length price.
Here we are discussing profit split method to determine profit shifted by one associated enterprise to the other.
Here we shall be discussing the transaction net margin method or TNMM in detail.
This is on rule 10AB of the Income Tax Act, 1961.
I am briefly touching transfer pricing issues in domestic transactions, which is not within the scope of this course.
In this lecture I shall cover publications of OECD on transfer pricing in a brief manner.
An APA or Advanced Pricing Agreement is an administrative approach that attempts to prevent transfer pricing disputes from arising by determining criteria for applying the arm's length principle to transactions in advance of those transactions taking place. We shall be discussing about APA in Indian tax jurisdiction here.
Here we shall be discussing the statistics on APAs
A new international tax structure is in the offing, which will address the issue of shifting of profits, particularly profits made by the Information Technology giants. The framework agreement has already been signed by 136 countries and jurisdictions. Implementation will take till December 2023 or may be a little beyond. This lecture gives you a brief idea of that. All my students, past, present and future should go through this lecture for a complete knowledge on international taxation.
This is the concluding lecture. Here I shall describe the latest amendments to the transfer pricing regulations applicable to India.
This course is on Transfer Pricing Regulations in India. This course is aimed at CA, CMA and MBA students who want to join the The Transfer Pricing Desks of the big 4 consultancy firms in India. You will learn here about the transfer pricing methods, methods of adjudication, advanced pricing agreements etc. To take full advantage follow the lessons sequentially. CAPTIONS are added to all the videos, so that my pronunciation or speaking style is understood with all clarity. Press the "CC" button to read the on screen captions. OECD or Organisation of Economic Co-operation and Development have made pioneering efforts on transfer pricing. Latest OECD guidance has also been discussed. I shall be updating the course with new information when the Budget 2021 is passed by the Indian Parliament. Similarly some of the developments on Transfer Pricing as and when it happens in OECD will also be incorporated. Once registered for the course, you will always remain updated on the subject. While following the course downloadable reference materials will be available. MCQs have been designed to reinforce your learning. In case you come across any difficulty please use the Udemy system to get clarification and answers from me. Let us say "Happy Learning."
Note : October 9, 2021 : A new international tax regime has been initiated at the behest of OECD yesterday. This framework agreement has been signed by 136 countries. After national level ratification and enactments, the full impact of the agreement will be felt from 2023 end. A new lecture 25 has now been added on this. All students past and present of this course must view this lecture.