A Practical Approach to Arm’s Length Pricing

Author:  Smarak Swain

Year: 2022

A Practical Approach to Arm’s Length Pricing provides a hands-on and technical guide to niche issues in transfer pricing. The first part of the book delves deep into the challenges faced in arm’s length pricing of transactions involving intangibles such as patents, know- how, copyrights, trademarks, exploitation rights and so on. It discusses the nuances of finding the arm’s length range of royalty rates, IP transfers, hard-to-value intangibles and marketing intangibles. The second part discusses new reforms in transfer pricing regimes around the world, fair transfer pricing policies in some typical industries, and issues such as comparability adjustments and benchmarking of corporate guarantee transactions.

There is a dearth of literature on the practical aspects of transfer pricing practice that A Practical Approach to Arm’s Length Pricing seeks to rectify. It discusses methods and models of benchmarking complex transactions, and goes on to demonstrate – step by step – how these methods and models can be used to arrive at the arm’s length standard. The nuances arising from assessment and litigation trends have also been highlighted.