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Transfer Pricing training courses
* Introduction & Applicability of Transfer Pricing,
* Comparison between Indian & OECD regulations,
* Associated Enterprise and International Transaction and
* Other nuances in Indian Transfer Pricing.
* Comparability Principles,
* Search of uncontrolled transactions,
* tested party concept, Economic Characterization
* General principles of documentation (including all limits under Section 92D)
* Issues faced in Functional Analysis and Risk Analysis
* Determination of ALP I
* Direct Comparable Uncontrolled Price Method,
* Resale Method,
* Other Method,
* Examples & Specific Issues & Problems faced while computing ALP in the respective method.
* Determination of ALP II Net Margin Method,
* Cost-plus Method,
* Split & Transaction,
* Preparation of Form No. 3CEB & issues relating to the same,
* Audit procedure,
* Management representation,
* Documentation with examples,
* Transfer pricing adjustments.
Use of Database:
* Search on a database with case studies,
* Benchmarking analysis
* Documentation u/s Rule 10D.
Recent TP Audit experience:
* Dealing with proceedings under the Dispute Resolution Panel (DRP) regime or ITAT or High Court proceedings
* Recent Assessment Issues
* Transfer of Intangibles,
* Tax treaties
* Cost contribution, Management Services / Cost Allocation,
* Advanced Pricing Arrangements and MAP, etc.
Recent Indian jurisprudence in transfer pricing (covering important cases, special benchmarked cases
Target Audience :
Managers/Senior Executives from
CA Dr. Mitil Chokshi
Past Chairman WIRC and merit lister of the CA examination.
Senior Partner, Chokshi & Chokshi, Mumbai
Doctorate in Developing Mumbai as a Global Financial Centre, World Benchmarking.
He has authored/co-authored following books on International Taxation,
Compendium on International Taxation (For CITC)
Business Process Outsourcing (For ICAI).
Mauritius International Business & Tax Strategies (Snow White publications)
Taxation of Non-Resident Indians (For BCAS).
Foreign Exchange Management Act, 1999 (FEMA) an Overview (For WIRC).
Investors Protection Handbook (ICAI).
Bank Branch Audit 1997 & 1996 (two editions For BCAS)
Speaker/Faculty at International & Domestic Forums
Presentations on IFRS, IT-enabled Auditing to MAINS at Mongolia
Presented paper on World Bank International Tendering at Cape Town, South Africa.
Presented paper on International Skills transfer at Berlin, Germany
Presented paper on Corporate Governance at London UK. etc.
Speaker at Bankers Training College-RBI, WIRC, BCAS, CITC, Rotary Club, Merchants Association, Public Sector Undertakings, Banks, etc.
The services clientele in Russia, Netherlands, Belgium, Mongolia, South Africa, USA, UK, Malaysia, Singapore, Mauritius, Seychelles
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