Decoding Transfer Pricing for Selling Functions

Key Features:

• Are some of the theories of OECD and UN around marketing intangibles sacrosanct?
• The same have been countered through qualitative and quantitative arguments.
• Quantitative arguments are based upon real life scenarios, with reference to statistical analyses on selected empirical data.
• Genesis of litigation around marketing intangibles analysed, along with solutions.
• Concept of royalties for licensed manufacturers explained in the context of regulatory regime of India.
• Practical solutions provided on harmonisation of transfer pricing and customs duty regulations in complex cases.
• Concept of attribution of profits to dependent agency permanent establishments explained, with reference to Berry Ratio.