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Decoding Transfer Pricing for Selling Functions

Decoding Transfer Pricing for Selling Functions

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Author: Rahul K Mitra
Year: 2020

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.
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