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.